Supreme Court Dismisses Review Petition in U.P. Milk Union Employment Dispute

The Supreme Court of India recently dismissed the review petition in Jagpal Singh vs. Chairman Administrative Committee, U.P. Milk Union & Dairy Federation Centralized Services. The petitioner had sought a review of the Court’s earlier ruling, which upheld the dismissal of his employment. The Court found no error apparent on record and rejected the review plea.

Background of the Case

The case revolved around an employment dispute involving Jagpal Singh, a former employee of the U.P. Milk Union & Dairy Federation Centralized Services. He was dismissed from service following disciplinary proceedings initiated by the Administrative Committee. The petitioner challenged this decision in the High Court, which ruled in his favor and quashed the dismissal order.

However, the Supreme Court, upon hearing the employer’s appeal, overturned the High Court’s ruling and upheld the dismissal order, stating that the punishment was based on correct appreciation of facts and law. Subsequently, the petitioner filed a review petition, arguing that the Court had committed errors in its judgment.

Legal Issues Raised

Whether the Supreme Court’s previous ruling contained an error apparent on record.
Whether the punishment imposed by the employer was justified.
Whether the review petition met the threshold for invoking the Court’s inherent jurisdiction.

Petitioner’s Arguments (Jagpal Singh)

The petitioner contended that the Supreme Court had erred in appreciating the facts and law while upholding the dismissal.
He argued that the disciplinary proceedings were flawed and violated principles of natural justice.
He claimed that the punishment was excessive and disproportionate to the alleged misconduct.
The petitioner also filed an application seeking action against the respondents under Section 340 of the Code of Criminal Procedure, alleging misconduct in legal proceedings.

Respondent’s Arguments (Chairman, Administrative Committee, U.P. Milk Union & Dairy Federation)

The respondents defended the dismissal, stating that it was based on a proper and fair disciplinary process.
They argued that the Supreme Court had already examined all aspects of the case and upheld the dismissal in its earlier ruling.
They contended that the review petition merely sought a re-evaluation of the Court’s judgment without pointing to any apparent error on record.
The respondents also opposed the petitioner’s application under Section 340 CrPC, calling it frivolous and devoid of merit.

Supreme Court’s Verdict

The Supreme Court, in a bench comprising Justices Uday Umesh Lalit, Hemant Gupta, and S. Ravindra Bhat, dismissed the review petition, reaffirming the validity of its earlier judgment.

The Court observed:

“After considering relevant provisions, by a detailed judgment, this Court found that the order of punishment passed by the Administrative Committee was based upon correct appreciation of facts and law and did not call for any interference.”

Key Observations by the Supreme Court

The Court ruled that the review petition did not establish any error apparent on record to justify interference.
The petitioner was essentially seeking a reconsideration of the merits, which is not permissible under the review jurisdiction.
The application for listing the review petition in open court was also rejected.
The petitioner’s application under Section 340 CrPC for alleged misconduct was dismissed as devoid of merit.

The Court concluded:

“The grounds raised in the Review Petition do not make out any error apparent on record to justify interference in Review Jurisdiction. This Review Petition is, therefore, dismissed.”

Final Order

The Supreme Court dismissed the review petition.
The application under Section 340 CrPC was also dismissed.
The previous ruling upholding the dismissal of the petitioner remained final.

Key Takeaways

Review petitions require an apparent error: The Court reaffirmed that a review petition is not an opportunity for re-arguing a case but must demonstrate a clear and obvious mistake.
Disciplinary decisions are given deference: Unless there is procedural unfairness or illegality, courts do not interfere with employer disciplinary actions.
Judicial finality is crucial: The ruling emphasizes that once the Supreme Court delivers a judgment, its reversal is only possible under exceptional circumstances.
Frivolous applications will be dismissed: The dismissal of the Section 340 CrPC application reiterates that baseless legal actions will not be entertained.

This judgment underscores the principle that review petitions must meet a stringent threshold and cannot be used to reargue cases decided on merits.

Petitioner Name: Jagpal Singh.
Respondent Name: Chairman, Administrative Committee, U.P. Milk Union & Dairy Federation Centralized Services.
Judgment By: Justice Uday Umesh Lalit, Justice Hemant Gupta, Justice S. Ravindra Bhat.
Place Of Incident: Uttar Pradesh.
Judgment Date: 13-12-2021.

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