The Madras High Court stepped in to clarify how far it can go when reviewing a bank’s disciplinary action. In R.J. Narayanan’s challenge against Indian Bank, the Court made it clear that it isn’t meant to re-read evidence or act like an appellate body. As long as the disciplinary and appellate authorities followed due process, their findings stand. The judgment also pushed back against routine remand orders, stressing that banking institutions rely on discipline, integrity, and accountability to protect public confidence.

Issue of Law: 

The limits of the High Court's power in judicial review over a bank’s disciplinary action: specifically, whether the Court can re-appreciate the evidence considered by the Disciplinary/Appellate Authorities, and whether orders of remand for fresh consideration should be passed as a matter of routine.

Brief Facts: 

The petitioner, R.J. Narayanan, an official of Indian Bank, filed a Writ Petition under Article 226 of the Constitution of India seeking a Writ of Certiorari to quash the records and order of the first respondent (Indian Bank's Appellate Authority). The Appellate Authority, which is the Deputy General Manager of the Vigilance Department, had issued an order confirming the disciplinary action taken against the petitioner by the Assistant General Manager/Disciplinary Authority.

Judgment: 

The Court disposed of the petition (upholding the disciplinary action, as inferred from the reasoning) by applying Supreme Court precedents. The Court held that:

1. The High Court cannot sit in re-appreciation of evidence which was duly considered by the Disciplinary/Appellate Authorities.

2. Remand orders for fresh consideration cannot be passed as a matter of routine. The Court emphasized the need for bank officials to perform their duties with absolute devotion, diligence, integrity, and honesty to maintain public confidence.

To read the full Judgment, click here

Court: In The High Court Of Judicature At Madras

Case Title: R.J.Narayanan V/s Indian Bank, rep. By its Deputy General Manager/ Appellate Authority & The Assistant General Manager/ Disciplinary Authority

Case no.: W.P.No.8321 of 2009

Bench: The Honourable Mr. Justice K. Surender

Date: Pronounced on 21/11/2025 (Reserved on 9/10/2025)