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2025 Supreme(Ori) 511

IN THE HIGH COURT OF ORISSA AT CUTTACK
S.K. SAHOO, SIBO SANKAR MISHRA, JJ.
Udaya Chandra Samal – Appellant 
Versus
Union of India and Others – Respondents
W.P. (C) No. 35074 of 2025
Decided On : 24-12-2025

Advocates Appeared:
For the Appellant : Suryasnata Mohapatra
For the Respondents: P.K. Parhi, Deepak Gochhayat

Disciplinary measures against employees must align with established conduct rules; negligence in critical safety roles justifies strict sanctions without judicial interference unless penalties shock judicial conscience.

Headnote:(A) Railway Services (Conduct) Rules, 1966 - Rule GR 2.08(1) - Disciplinary action - Petitioner challenged the orders of punishment for leaving duty without permission, leading to significant safety hazards. Court upheld that neglect in duty on vital safety posts justifies disciplinary proceedings. (Paras 10, 12, 16)

(B) Judicial review - The role of the court in reviewing disciplinary measures is limited to ensuring proportionality and avoiding outcomes that shock judicial conscience. (Paras 13, 14)

Facts of the case:
The petitioner, a Station Superintendent, was punished for leaving his duty station unattended, which had serious implications for train safety and punctuality. This negligence resulted in a passenger train being allowed into an occupied block section.

Findings of Court:
The court confirmed the disciplinary actions taken were in accordance with the rules due to the substantial hazards posed by the petitioner's negligence.

Issues: The key issues included the legality of the punishment, adherence to procedural rules during disciplinary proceedings, and the justifiability of the penalty.

Ratio Decidendi: The court stated that mere dissatisfaction with punishment does not warrant interference unless the punishment is shockingly disproportionate or perverse, reaffirming that the discretion lies with disciplinary authorities.

Result: Writ petition dismissed.

Table of Content
1. challenging disciplinary orders by the petitioner. (Para 2 , 3 , 4 , 5 , 6)
2. discussion on the justification and implications of conduct rules violations. (Para 8 , 10)
3. judicial review limitations on disciplinary actions. (Para 9 , 11 , 12 , 16)
4. disciplinary authorities' exclusive rights to determine penalties. (Para 13 , 14 , 15)
5. writ petition dismissed; no grounds for interference. (Para 17 , 18)

ORDER :

1. This matter is taken up through Hybrid arrangement (video conferencing/physical mode).

2. The petitioner has filed this writ petition challenging the order dated 26.03.2025 passed by the learned Central Administrative Tribunal, Cuttack Bench, Cuttack (for short, “Tribunal”) in O.A. No.265 of 2021, as well as the orders dated 01.08.2019, 10.09.2020 and 09/16.04.2021 passed by the Disciplinary Authority, Appellate Authority and Revisional Authority respectively. The petitioner has also prayed for modification of the punishment imposed upon him and for restoration of his pay, seniority and other consequential service benefits.

3. The petitioner filed the aforesaid Original Application, wherein he sought the following reliefs:

“(i) To quash the order of punishment dated 01.08.2019 passed by the Disciplinary Authority under Ann.-A/4 series;

(ii) And to quash the order dated 10.09.2020 & 09/16.04.2021 under Ann.-A/8 & A/10 passed by the Appellate & Revisionary Authority;

(iii) And to direct the respondents to restore the pay and position in the seniority as a Station Superintendent.”

4. After filing of the said Original Application, notice was issued to the opp. parties, who filed counter affidavit, stating, inter alia, that the petitioner, since his appointment has been working in different safety-related posts, like Asst. Station Master, Station Superintendent etc., which are very crucial for ensuring the safety of train operations. It is further stated that he was required to remain vigilant at all times while on duty and could leave the working spot only in case of emergency after taking all safety precautions, including informing the on-duty Section Controller and securing safety keys and block instruments. It was further stated that despite being aware that Train No.58418 was scheduled to arrive at the station where the petitioner was on duty, he left his working spot without taking any safety precautions for maneuvering the incoming train. Such an act, according to the opposite parties, could have resulted in a train collision and loss of human lives. Further, his negligence led to loss of coaching punctuality due to detention of the said train for about 33 minutes at Pathapatnam Station. It was further stated that on 29.11.2018, a passenger train was allowed into an occupied block section already occupied by a material train due to the sheer irresponsibility of the petitioner. The said unusual incident is defined as an indicative accident under the relevant manual provisions, having serious potential hazards. The consequences thereof are provisioned with severe punishment to prevent recurrence and to ensure safety in train operations. It was further stated that the disciplinary proceedings were conducted in accordance with the rules and that the petitioner was afforded full opportunity to defend himself. The Disciplinary Authority, Appellate Authority and Revisional Authority, after considering the relevant records, passed the impugned orders.

5. Pursuant to the counter affidavit filed by the opp. parties, the petitioner filed a rejoinder affidavit, stating, inter alia, that the incident was within the knowledge of the Station Masters of Gunupur and Nuapada, as well as other staff of Parlakhemundi Railway Station, but no one reported the incident dated 29.11.2018 to the Chief DTI. It was stated that the Chief DTI came to Gunupur on 01.12.2018 for an inquiry and also inspected Parlakhemundi Station along with SSE Radheyshyam, as reflected in the records. According to the petitioner, the Chief DTI was awa

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