On 1 November 1995, a three-judge Bench restated the limited scope of judicial review of departmental discipline — review of the manner of decision, not an appeal on merits — and confined interference with the quantum of punishment to penalties that shock the conscience of the court.
On 1 October 1993, a five-judge Constitution Bench held that a delinquent employee is entitled to a copy of the inquiry officer's report before the disciplinary authority decides — but tempered the remedy with a prejudice test, making non-supply void only where the employee shows prejudice.
On 19 December 2008, the Supreme Court held that a departmental enquiry finding cannot rest on the inquiry officer's ipse dixit, surmise or conjecture — that suspicion is never a substitute for legal proof, and that disciplinary orders carrying civil consequences must be supported by recorded reasons.
On 19 October 1962, a five-judge Constitution Bench laid the foundation of the 'some evidence' rule in service discipline — holding that a High Court will not upset a departmental penalty supportable on a surviving finding of substantial misconduct, even if another finding is defective.
On 11 July 1985, a five-judge Constitution Bench upheld the second proviso to Article 311(2) — the three situations in which a civil servant may be dismissed without the constitutional inquiry — while holding the recorded satisfaction reviewable by courts for relevance and bona fides.