Court Cannot Substitute Punishment — Disciplinary Authority Must Reconsider Quantum: Jharkhand HC
The Court judgment reinforces the principle of proportionality in disciplinary actions and affirms that while disciplinary authorities have the prerogative to impose penalties, courts will intervene only when the punishment is manifestly unjust.
The Jharkhand High Court has reiterated that courts cannot substitute disciplinary penalties with their own, even when the punishment appears disproportionate. Instead, the appropriate course is to remit the matter back to the disciplinary authority for reconsideration.
A Division Bench of the High Court dismissed an appeal filed by the State of Jharkhand challenging a Single Judge’s decision in the case of State of Jharkhand v. Meena Kumari Rai (L.P.A. No. 134 of 2025). The Single Judge had set aside the removal of Meena Kumari Rai, a senior education officer, and directed the disciplinary authority to reassess the quantum of punishment.
Rai, who joined the Bihar Education Service in 1988 and was later allotted to Jharkhand after the state’s bifurcation, was removed from service following an inquiry that found her guilty of financial irregularities, administrative negligence, and harassment of subordinates during her tenure as District Education Officer (DEO), Palamau.
Challenging the removal, Rai approached the High Court, arguing that the punishment was excessive. The Single Judge ruled in her favor, prompting the state to file an appeal.
Upholding the earlier decision, the Division Bench cited Supreme Court precedents on proportionality of punishment and stated, “It is not open to the Court to substitute the punishment on its own. The appropriate course would be to remit the matter to the disciplinary authority for reconsideration, so as to maintain a proper balance between the gravity of the charge and the punishment imposed.”
The Bench emphasized that judicial review under Article 226 of the Constitution allows interference only when the punishment “shocks the conscience of the Court.” Even then, courts must limit their role to directing reconsideration, not imposing alternative penalties.
The Court also noted Rai’s 31 years of unblemished service and the absence of any allegation of embezzlement of public funds. It held that denying her all pensionary benefits would be unduly harsh and found no reason to interfere with the Single Judge’s order.
The appeal was dismissed, and the disciplinary authority was directed to reconsider the punishment afresh.
The judgment reinforces the principle of proportionality in disciplinary actions and affirms that while disciplinary authorities have the prerogative to impose penalties, courts will intervene only when the punishment is manifestly unjust. For further insights into the evolving workplace paradigm, visit
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