Madras High Court· 23 September 2026

Can disciplinary findings be interfered with in judicial review unless perverse, rendered by an incompetent authority, or contrary to the materials on record?

V.VARADHARAJAN v. THE STATE OF TAMIL NADU

WP.26722/2024 · 2026:MHC:3973 · WP No. 26722 of 2024
Coram: Justice C.Kumarappan

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Answer

Disciplinary findings cannot be interfered with in judicial review unless perverse, rendered by an incompetent authority, or contrary to the materials on record.

No. Disciplinary findings cannot be interfered with in judicial review unless perverse, rendered by an incompetent authority, or contrary to the materials on record. The concurrent findings of the Disciplinary, Revisional and Reviewing Authorities rested on the record, and the co-delinquent had received the same punishment.

Headnote

Disciplinary Authority — Charge memorandum — Secretary of Society — Misappropriation — Compulsory retirement — Judicial review — Scope of interference — Disciplinary proceedings — Secretary of Society — Misconduct through subordinates — Held: A Secretary at the helm of affairs of a Society cannot absolve his responsibility by attributing the entire misconduct to his subordinates; faced with a shortage of staff, he ought to have brought it to the notice of the higher authorities. (¶6, 9) Disciplinary proceedings — Misappropriation — Admitted shortage of funds — Held further: Where the delinquent admitted the shortage of funds and the transactions were carried out under his signatures, the finding of misappropriation cannot be faulted, even though he made good the loss. (¶7, 8) Judicial review — Findings of Disciplinary Authority — Limited scope — Held further: The scope of interference in judicial review is limited, and findings based on the materials on record that are not perverse cannot be interfered with. Writ Petition dismissed. (¶9, 10, 11)

Headnote

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In the Court's own words

Paragraph 9It is also relevant to mention that the petitioner cannot absolve himself of responsibility merely by referring to the misconduct of his subordinates, particularly when the co-delinquent was also imposed with the punishment of compulsory retirement. Therefore, this Court is of the firm view that the findings rendered by the Disciplinary Authority, the Revisional Authority and the Reviewing Authority are well-founded. It is relevant to reiterate that, while exercising the power of judicial review, the scope of interference is limited. Unless the findings rendered by the Disciplinary Authority are perverse, rendered by an incompetent authority, or contrary to the materials available on record, this Court cannot interfere with such findings.

Paragraph 10In the case in hand, as stated hereinabove, the findings rendered by the authorities are based on the materials available on record and cannot be said to be perverse. Therefore, this Court does not find any ground to interfere with the impugned orders.

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Also decided in this judgment

Can a Secretary at the helm of affairs of a Society absolve his responsibility by attributing the entire misconduct to his subordinates?Can a finding of misappropriation be faulted where the delinquent admitted the shortage of funds and the transactions were carried out under his signatures?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections