K. Samba Moorthy v. Sanjiv Chadha & Ors.
The Supreme Court's decision in K. Samba Moorthy v. Sanjiv Chadha & Ors. on January 27, 2025, marks a significant development in employment law, particularly concerning retrospective promotions and the rights of employees subjected to flawed disciplinary proceedings.
Case Background
K. Samba Moorthy joined the Bank of Baroda as a Probationary Officer in 1983 and ascended to the position of Manager (Scale-II) by 1992. While serving as a Branch Manager in Gujarat, he faced show-cause notices in 1999 and 2000 for alleged irregularities. Subsequently, a charge sheet was issued in 2000, leading to disciplinary proceedings. During this period, Moorthy's promotion from Scale-II to Scale-III was withheld due to the pending inquiry. In 2001, a minor penalty was imposed, reducing his pay by one stage for three years without cumulative effect.
His appeals against this penalty were unsuccessful, and in 2002, his promotion was officially canceled. Moorthy challenged the disciplinary actions in 2008, and in 2017, the High Court set aside the proceedings, citing bias, and granted him consequential benefits. Despite this, the bank only refunded the deducted pay amounting to ₹19,446, without addressing the promotion aspect. This led Moorthy to file a contempt petition, which was dismissed by the High Court, prompting the appeal to the Supreme Court.
Supreme Court's Observations
The Supreme Court recognized that the fundamental defect in the disciplinary inquiry was not attributable to Moorthy. The inquiry was conducted by a junior officer who was also a candidate for the same promotion, presenting a clear case of potential bias. The bank acknowledged this defect by not contesting the High Court's decision. The Court emphasized that Moorthy had been unjustly deprived of his rightful promotion due to no fault of his own and had endured a prolonged legal battle spanning over two decades.
Judgment
The Court ordered that Moorthy be granted promotion to Manager Grade-III effective from July 28, 2001, with all associated monetary benefits. It clarified that the term "consequential benefits," as used in the High Court's judgment, encompassed the promotion and its financial advantages. The bank was directed to implement this order within four weeks, including payment of arrears with interest at 6% per annum from the dates the benefits were due.
Implications
This judgment underscores the judiciary's commitment to upholding fairness in employment practices. It highlights that employees should not suffer due to procedural flaws in disciplinary proceedings, especially when such flaws are beyond their control. The decision also clarifies that when a court sets aside disciplinary actions and grants consequential benefits, it includes not only rectification of penalties but also rightful considerations like promotions and associated financial entitlements.
In essence, the ruling in K. Samba Moorthy v. Sanjiv Chadha & Ors. serves as a precedent ensuring that employees are protected from unjust administrative actions and are duly compensated for unwarranted delays and denials in their career progression.
