1. Meaning of Manager Approval Requirements

Manager approval requirements refer to organisational rules under which certain employment, financial, disciplinary, operational, or administrative decisions cannot be implemented unless the designated manager or competent authority gives prior approval.

Examples include:

• Recruitment and appointment
• Leave and attendance exceptions
• Overtime
• Salary revisions and incentives
• Promotions and transfers
• Disciplinary action
• Termination of employment
• Expense reimbursement
• Procurement
• Payroll changes
• Performance ratings
• Remote-work or location changes
• Access to confidential systems

The requirement is primarily a governance and internal-control mechanism. However, managerial approval cannot override mandatory provisions of labour legislation, standing orders, service rules, natural justice, or contractual rights.

2. Why Manager Approval Is Required

A. Accountability

Approval establishes who authorised a particular decision. This is particularly important where a decision affects:

• employee compensation,
• employment status,
• company property,
• disciplinary consequences, or
• statutory compliance.

B. Internal control

A company may require multiple levels of approval to prevent unauthorised decisions.

For example:

HR recommendation → Reporting Manager → Department Head → HR → Competent Authority

C. Delegation of authority

Managers generally exercise powers delegated to them by:

• employment policies,
• service regulations,
• standing orders,
• board resolutions,
• organisational rules, or
• appointment/authorisation documents.

A manager should therefore act within the scope of delegated authority.

D. Evidence in disputes

An approval trail can become important evidence when a dispute later arises concerning:

• termination,
• promotion,
• salary,
• disciplinary proceedings,
• transfer,
• leave,
• reimbursement, or
• performance evaluation.

3. Manager Approval and Employment Decisions

Managerial approval becomes particularly significant when an employer takes action affecting an employee's substantive rights.

For example, if a company policy states that termination requires approval from the competent authority, a reporting manager ordinarily should not independently issue a termination order merely because the manager recommends termination.

The distinction is:

Recommendation ≠ Approval ≠ Final statutory authority

A manager may recommend an action, while another designated authority may possess the power to approve or implement it.

4. Approval Must Come From the Competent Authority

An important legal principle is that an authority exercising statutory or delegated power must act within the authority given to it.

Therefore, an organisation should clearly specify:

The precise authority depends upon the applicable law, service rules, standing orders, contract and organisational delegation.

5. Approval Cannot Legalise an Otherwise Illegal Action

Managerial approval is not a substitute for compliance with law.

For example, suppose a manager approves dismissal of an employee. If the dismissal violates applicable statutory requirements or principles of natural justice, the fact that the manager signed an approval form does not automatically make the dismissal lawful.

Similarly, an internal policy cannot authorise conduct prohibited by mandatory legislation.

6. Manager Approval and Natural Justice

Where an employment decision has disciplinary consequences, approval procedures must be distinguished from the disciplinary process itself.

Depending on the applicable service rules/statute, procedural safeguards may include:

1. allegation/charge,
2. notice,
3. opportunity to respond,
4. domestic enquiry where required,
5. consideration of evidence,
6. reasoned decision,
7. appropriate penalty,
8. appeal/review where available.

A manager's approval cannot simply replace these mandatory procedural safeguards.

7. Manager Approval in Termination

Termination is one of the areas where approval requirements can become legally significant.

If the applicable employment framework requires action by a particular authority, termination by an unauthorised person may be challenged.

However, the legal consequences depend upon the employee's status and applicable law. Different principles may apply to:

• government employees,
• workmen under labour legislation,
• employees governed by certified standing orders,
• contractual employees,
• managerial/supervisory personnel, and
• employees of private establishments governed by contract and applicable state law.

8. Six Important Case Laws

Case 1 — State of Uttar Pradesh v. Mohammad Nooh

AIR 1958 SC 86

Principle

The Supreme Court considered the consequences of serious defects in a disciplinary proceeding.

The case is important for the proposition that where a disciplinary process is fundamentally defective, the existence of a formal order does not necessarily cure the underlying legal defect.

Relevance to manager approval

An organisation should not treat managerial approval as a substitute for a legally valid disciplinary process.

If the underlying procedure violates fundamental procedural requirements, merely obtaining approval from a senior manager may not cure the defect.

Key takeaway

Approval does not automatically cure a defective disciplinary process.

Case 2 — State of Uttar Pradesh v. Shatrughan Lal

(1998) 6 SCC 651

Principle

The Supreme Court emphasised the importance of providing a meaningful opportunity to defend oneself in disciplinary proceedings.

The Court examined procedural fairness where an employee was proceeded against without adequate opportunity.

Relevance

A manager may recommend disciplinary action, but the employer must follow the applicable disciplinary rules.

Managerial approval cannot be used to bypass the employee's procedural rights.

Key takeaway

Internal approval must operate within the framework of natural justice and applicable service rules.

Case 3 — Managing Director, ECIL v. B. Karunakar

(1993) 4 SCC 727

Principle

This is a leading Supreme Court decision concerning disciplinary proceedings and the employee's right to receive the enquiry report before the disciplinary authority takes the final decision, subject to the principles laid down by the Court.

The judgment strongly emphasises procedural fairness in disciplinary action.

Relevance to manager approval

Suppose:

Manager → recommends dismissal → senior manager approves dismissal.

That sequence alone does not establish a legally valid disciplinary process where statutory/service rules require additional procedural safeguards.

The competent authority must consider the matter in accordance with the applicable procedure.

Key takeaway

The final approving authority must act within the prescribed disciplinary procedure; approval is not merely a mechanical formality.

Case 4 — Union of India v. H.C. Goel

AIR 1964 SC 364

Principle

The Supreme Court examined the relationship between disciplinary findings and the authority imposing punishment.

The case is significant for judicial scrutiny of disciplinary action where the material supporting the conclusion is inadequate.

Relevance

A manager's approval should be based upon the relevant record and applicable disciplinary framework.

A superior authority cannot assume that a manager's recommendation is automatically conclusive.

Key takeaway

Approval of disciplinary action requires lawful consideration of the relevant material and applicable rules.

Case 5 — Roop Singh Negi v. Punjab National Bank

(2009) 2 SCC 570

Principle

The Supreme Court stressed that disciplinary findings must have an evidentiary foundation. The Court criticised reliance upon material that had not been properly established in the disciplinary process.

Relevance to manager approval

A manager cannot simply state:

"The employee committed misconduct; therefore termination is approved."

There must be an appropriate evidentiary and procedural foundation under the applicable employment rules.

Key takeaway

Managerial approval should rest upon a properly conducted disciplinary process and relevant evidence.

Case 6 — State Bank of India v. R. Periyasamy

(2015) 3 SCC 101

Principle

The Supreme Court considered disciplinary proceedings and the scope of judicial review concerning disciplinary punishment.

The judgment illustrates that disciplinary authorities possess a role in evaluating misconduct and imposing appropriate punishment, subject to applicable legal standards and judicial review.

Relevance to manager approval

An organisation should identify clearly:

• who is the disciplinary authority,
• who may issue the charge-sheet,
• who conducts the enquiry,
• who makes the disciplinary decision,
• who approves the punishment, and
• who hears the appeal.

A person who merely has managerial responsibility is not necessarily the legally designated disciplinary authority.

Key takeaway

Managerial position by itself does not necessarily confer disciplinary authority.