Punjab National Bank Employee Dismissal Case: Supreme Court Verdict Explained

The case of M.L. Singla vs. Punjab National Bank revolves around the dismissal of an employee, M.L. Singla, who was a cashier at Punjab National Bank’s branch in Jind. The dismissal was based on charges of consuming liquor while on duty and a cash shortage of Rs. 35,000. The case traveled from departmental inquiry to the Labour Court, the High Court, and finally, the Supreme Court.

Background of the Case

On 21st March 1984, M.L. Singla was found consuming liquor at his workstation. Additionally, a cash shortage of Rs. 35,000 was detected in the daily accounts. The bank initiated disciplinary proceedings, serving him a charge sheet on 11th October 1985. The charges were:

• Consumption of liquor while on duty.
• Cash shortage of Rs. 35,000, indicating negligence.

Following an internal inquiry, both charges were found valid. The bank subsequently dismissed Singla on 29th August 1987. The appeal to the bank’s appellate authority was also dismissed on 26th February 1988.

Labour Court’s Verdict

Singla then sought recourse through the Industrial Disputes Act, leading to a reference to the Labour Court in 1989. The Labour Court ruled in his favor, terming the inquiry as perverse and granting reinstatement with 50% back wages.

High Court’s Ruling

Punjab National Bank challenged this decision in the High Court, which set aside the Labour Court’s award. It upheld the dismissal order, stating that the misconduct was serious and warranted termination.

Supreme Court Judgment

The Supreme Court upheld the High Court’s ruling but provided its own reasoning:

• The Labour Court failed to first determine the legality of the domestic inquiry before assessing evidence.
• The Labour Court improperly acted as an appellate body by reassessing the evidence.
• Back wages should only be awarded if the employee proves he was not gainfully employed, which Singla did not establish.
• Both charges were serious enough to justify dismissal.

The Supreme Court stated, “No employer would tolerate an employee consuming liquor while on duty.” It also held that a cashier is directly responsible for cash shortages and that the punishment of dismissal was appropriate.

Conclusion

This case reaffirms the principle that courts should respect findings of domestic inquiries unless they are proven to be flawed. The ruling clarifies that Labour Courts must first assess the validity of inquiries before intervening in dismissals. Employers have the right to enforce discipline, and serious misconduct justifies strict penalties.

Petitioner Name: M.L. Singla.
Respondent Name: Punjab National Bank and Anr..
Judgment By: Justice Abhay Manohar Sapre, Justice S. Abdul Nazeer.
Place Of Incident: Jind, Punjab.
Judgment Date: 20-09-2018.

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