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Supreme Court Quashes Patna HC Ruling, Upholds SBI's Removal of Employee in Loan Corruption Case

Shivam Y.

State Bank of India & Others vs. Ramadhar Sao - Supreme Court restores SBI employee’s removal, overturning Patna HC order of reinstatement, stressing limits of judicial review in service matters.

Supreme Court Quashes Patna HC Ruling, Upholds SBI's Removal of Employee in Loan Corruption Case

The Supreme Court has overturned the orders of the Patna High Court that had reinstated a former State Bank of India employee accused of corruption. Delivering its verdict on 20 August 2025, a Bench of Justice Rajesh Bindal and Justice Manmohan restored the earlier decision of the bank's Appellate Authority which had ordered "removal from service with superannuation benefits."

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Background of the Case

The dispute traces back to 2008, when complaints surfaced against Ramadhar Sao, then working as a messenger in SBI's Agriculture Development Branch, Ramnagar. Allegations included acting as a middleman in loan sanctions and taking money from customers. An internal inquiry found him guilty, leading to dismissal in January 2011. On appeal, the bank showed leniency by reducing the penalty to removal with retirement benefits.

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Unhappy with this, Sao approached the Patna High Court. In 2018, a Single Bench directed his reinstatement with back wages, also granting the bank liberty to hold a fresh inquiry. The Division Bench later upheld this decision, prompting SBI to approach the apex court.

The Supreme Court strongly disagreed with the High Court’s approach. It clarified that judicial review in service disciplinary cases is limited to checking procedural fairness, not re-examining evidence like an appellate authority.

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Quoting from earlier rulings, the Bench observed:

"The power of judicial review… is circumscribed by limits of correcting errors of law or procedural errors leading to manifest injustice or violation of principles of natural justice, and it is not akin to adjudication of the case on merits."

The judges noted that multiple loan beneficiaries had testified to paying illegal gratification to the respondent, and Sao himself had indirectly admitted guilt by pleading for forgiveness before the disciplinary authority.

By restoring the punishment of removal with superannuation benefits, the Court emphasised that even Class IV staff can be held accountable when found facilitating corruption. At the same time, the compassionate view taken earlier by the bank - granting retirement benefits instead of outright dismissal - was upheld.

Case Title: State Bank of India & Others vs. Ramadhar Sao

Case Number: Civil Appeal No. 10680 of 2025

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