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It is difficult to prove but not impossible. The degree of proof needed in a Departmental Procedure is less than what is needed in law. Outsiders cannot be summoned but their statements can always be recorded by any two officers. Also without a complainant such actions would not proceed. The complainant can be of use. But in granting punishment there has to be a human face and law. You may read the following blog for an example of how punishments are imposed.