K. Samba Moorthy vs. Sanjiv Chadha
Citation: 2025 INSC 110; Civil Appeal arising out of SLP (C) No. 10245 of 2024
Bench: Justice B.R. Gavai, Justice K.V. Viswanathan
Background
K. Samba Moorthy, a long-serving officer of Bank of Baroda, faced disciplinary proceedings in 2000-01 for alleged irregularities while serving as Branch Manager. During this period, his promotion from Scale-II to Scale-III was withheld. In 2001, a minor penalty was imposed—reduction in pay by one stage for three years without cumulative effect. His appeals failed, and in 2002, his promotion was formally canceled. Moorthy challenged the disciplinary proceedings in 2008; the High Court quashed the inquiry in 2017, finding clear bias as a junior officer was appointed as the enquiry officer. The Single Judge granted "consequential benefits," but the bank only refunded the deducted pay and did not restore the promotion. Moorthy’s contempt petition seeking further relief was dismissed by the High Court, leading to the appeal before the Supreme Court.
Key Legal Issues
Whether Moorthy was entitled to retrospective promotion and monetary benefits as "consequential benefits" after the disciplinary proceedings were set aside.
Whether the contempt court could grant reliefs not expressly adjudicated in the original writ order.
Whether cancellation of promotion, not specifically challenged earlier, could be revisited.
Supreme Court’s Analysis
The Court acknowledged that the disciplinary proceedings were vitiated by bias, not attributable to Moorthy, and the bank did not contest this before the Division Bench. The defect was fundamental and accepted by the employer.
The Court noted that while the Single Judge’s order granted "consequential benefits," it did not explicitly direct restoration of promotion. Moorthy had not challenged the 2002 cancellation of promotion in his writ petition, and the High Court had not adjudicated this aspect.
Relying on precedents (Union of India v. K.V. Jankiraman, Bachhaj Nahar v. Nilima Mandal), the Court held that relief not specifically pleaded or adjudicated cannot be granted in contempt proceedings. The contempt court cannot go beyond the original order.
The Court observed that Moorthy had already received monetary compensation for the penalty and had been promoted in 2012. Claims for further or higher promotions were not sustainable, as these were not part of the original litigation.
Decision
The Supreme Court partly allowed the appeal, setting aside the High Court’s contempt judgment, but declined to grant retrospective promotion or additional benefits beyond the pay restoration already provided. The Court underscored that the scope of contempt proceedings is limited to enforcing the original order and cannot be used to seek new or expanded reliefs.
Significance
This judgment clarifies that while employees are entitled to relief when disciplinary proceedings are vitiated by procedural defects, courts cannot grant unclaimed or unadjudicated reliefs in contempt proceedings. It reinforces the limits of consequential benefits and the principle that only pleaded and adjudicated claims can be enforced.
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