Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Mad) 820

IN THE HIGH COURT OF JUDICATURE AT MADRAS
R.SURESH KUMAR, V.LAKSHMINARAYANAN, JJ.

State Bank of India, Mumbai – Appellant
Versus
S. Kalavathi – Respondent
W.A. No.3674 of 2025 & CMP. No.30274 of 2025
Decided On : 05-01-2026

Advocates Appeared:
For the Appellants : Mr. C. Mohan for M/s. King and Partridge
For the Respondent: Ms. Vaigai, Senior Counsel for Ms. Anna Mathew.

Termination of service based on unsubstantiated claims against previous employment violated natural justice; failure to conduct a fair enquiry prior to dismissal rendered the termination unlawful.

Headnote:(A) State Bank of India Officers’ Service Rules, 1992 - Rule 16(3)(a) - Termination of service - The petitioner’s appointment was challenged based on alleged misconduct during prior employment; however, no FIR or valid investigation substantiated the claims against her. The Single Judge ruled that withholding of adverse report violated principles of natural justice, necessitating a proper enquiry. (Paras 17, 18, 30, 32)

(B) Employment Law - The petitioner’s dismissal for alleged suppression of facts was deemed invalid as the respondents failed to prove knowledge of any pending charges or FIR.

Facts of the case:
The petitioner, after joining as a probationary officer, was terminated based on an adverse report regarding prior employment that alleged misconduct. She denied any wrongdoing or knowledge of any FIR against her. (Paras 4-6, 11)

Findings of Court:
The Single Judge found in favor of the petitioner, ruling no material facts were suppressed, and that her termination was punitive without a fair enquiry. The honor meant a stigmatising impact on her future employment. (Paras 18-19, 59)

Issues: The main issues included the legality of the termination without a proper enquiry and whether the petitioner suppressed relevant facts regarding her employment history. (Paras 27, 58)

Ratio Decidendi: The court emphasized that accusations must be substantiated and that employment dismissals should not occur without proper adherence to disciplinary investigations as per set rules and natural justice principles. (Paras 24, 28, 32)

Result: Writ appeal dismissed.

Table of Content
1. employment recruitment process details. (Para 3 , 4 , 5 , 6 , 7)
2. arguments regarding appointment termination. (Para 10 , 11 , 12 , 15)
3. court's reasoning on process and fairness. (Para 18 , 19 , 24 , 40)
4. indications of legal precedents and their application. (Para 22 , 25 , 36 , 39)
5. dismissal of appeal due to lack of merit. (Para 60)

JUDGMENT :

V. LAKSHMINARAYANAN, J.

The present appeal arises against the order of the learned Single Judge of this Court in W.P.No.650 of 2022 dated 09.04.2025.

2. The appellants are the respondents before the writ court. For the sake of convenience, the parties shall be referred to as per their ranks in the writ petition.

3. The writ petitioner applied pursuant to a recruitment notification issued by the respondents on 27.07.2020. The petitioner was called upon to take up a written examination and also an interview. The petitioner was successful in both the examinations and was issued an order of appointment on 12.03.2021. A joining order was issued by the respondents calling upon the petitioner to join in the Chennai Circle as a Circle Based Officer on 21.06.2021. The petitioner was kept on six months’ probation.

4. On 19.08.2021, the petitioner was informed by the Regional Manager, State Bank of India, Chengalpet that it had come to their knowledge that her previous employer, namely, ICICI Bank Limited, Puducherry had initiated a case against her and an FIR had been registered. She was called to produce a copy of the FIR and to furnish the details of the case. The petitioner submitted her explanation on 26.08.2021. In the said explanation, she informed that she has not received any official communication regarding the case filed against her or registration of the FIR. She added that she came to know about the alleged FIR only from the communication issued by the respondents. She declared that she had never been involved in any case and that, she had written to the HR team of ICICI Bank to clear her name. She assured that she will share the same as soon as she gets the details from them. She asserted that she confirmed from the Police Departments of the States of Tamil Nadu and Puducherry that no case has been filed against her. She attached the copies of her relieving letters, conduct certificates and the contact details of the reporting authorities of their previous assignments.

5. The Chief Manager (Compliance and Risk Management) of State Bank of India, Puducherry made an enquiry with the ICICI Bank, Puducherry and forwarded a report. This report was sent on 30.09.2021 and it is stated that the Chief Manager (C & O) had enquired with the Deputy Branch Manager, ICICI Branch, Puducherry on 28.09.2021 and from such enquiry, it came to his knowledge that the petitioner had misappropriated the funds of a senior citizen and a complaint had been lodged by his son with the Bank. The enquiry report further stated that the Risk Containment Unit of ICICI Bank had lodged a complaint against the writ petitioner but the details and the findings of the FIR have not been shared by the Risk Containment Unit with the Puducherry Branch. The enquriy report further stated that even before initiation of the enquiry, the writ petitioner submitted her resignation and left the services of the ICICI Bank.

6. Acting on the report so submitted, a show cause notice was issued to the petitioner on 21.10.2021. On 25.10.2021, the petitioner issued a reply reiterating the contentions that she had raised earlier. She also requested the bank to share the adverse referee report so as to enable her to verify the same with the ICICI Bank and give a proper explanation thereto. On the very same day, the respondents replied that the referee report/previous employer’s report is a confidential document and the same cannot be shared. It is on record that on 21.06.2021, the Grand Bazaar Police Station issued a certificate stating that the petitioner had not been convicted in any criminal case and no adverse remarks ha