A debarment for impersonation requires corroborative evidence beyond photo-analysis showing a 98% match.

The applicant, Mohit, appeared in the Multi-Tasking (Non-Technical) Staff Examination, 2020 under Roll No. 2201338912 and was declared qualified. He secured Rank No. 27 and was allocated the Directorate of Plant Protection, Quarantine & Storage, Faridabad; however, his dossier was withheld because the Staff Selection Commission alleged a mismatch between his application-time photograph and examination-time photograph

The Commission’s photo-analysis report dated 22.12.2023 allegedly identified a mismatch and led to a show-cause notice dated 19.03.2024, granting the applicant ten days to respond. The applicant submitted his reply dated 23.03.2024 and subsequently made a representation dated 04.04.2024, contending that the photographs had been taken at different points in time and that the Commission’s own report showed a 98% match between them

The Commission rejected the applicant’s explanation, cancelled his candidature, and, by order dated 03.07.2024, debarred him from appearing in its examinations for seven years. The applicant challenged the order under Section 19 of the Administrative Tribunals Act, 1985, seeking quashing of the debarment, verification through comparison of his identity with CCTV footage, and consequential consideration for appointment

Whether the Commission’s order dated 03.07.2024, debarring the applicant for seven years on the basis of alleged photographic mismatch, was vitiated by non-application of mind and failure to consider his explanation and the 98% photo match recorded in the Commission’s own report?

Whether an alleged mismatch between the application-time and examination-time photographs, without further corroborative material establishing impersonation, could sustain cancellation of candidature and seven-year debarment?

Whether the applicant was entitled to restoration of his candidature and consequential appointment-related benefits in view of his prior allocation to the User Department?

The Tribunal exercised jurisdiction under Section 19 of the Administrative Tribunals Act, 1985. It considered Clauses 19.1, 20 and 14.2 of the examination notice, which empowered the Commission to act against impersonation and malpractice, made its decision-making authority final in examination matters, and provided that candidature would remain provisional pending scrutiny.

The Tribunal held that these provisions did not dispense with the requirement of fair consideration, application of mind, and a reasoned decision. It distinguished Yattin Dutt Kaushik v. Staff Selection Commission & Anr., where debarment was supported by a CFSL forensic opinion showing handwriting and signature mismatches; in the present case, there was no comparable expert or corroborative evidence, and the Commission’s own photo-analysis report recorded a 98% match.

The governing principle was that administrative power to punish examination malpractice must be exercised on relevant and reliable material, after properly considering the candidate’s explanation; suspicion based merely on photographic variation cannot, without more, establish impersonation.

The Tribunal found that the Commission was competent to investigate and take action in cases of suspected impersonation. However, the impugned order did not demonstrate that the applicant’s specific defence had been meaningfully considered. The applicant had expressly explained that the photographs were taken at different times, while the Commission’s own report showed a 98% similarity between them.

Despite this material circumstance, the order proceeded primarily on the assertion of photographic mismatch and did not identify any independent or corroborative evidence of impersonation. Unlike the forensic evidence available in Yattin Dutt Kaushik, the photo-analysis report here did not substantiate impersonation; rather, its 98% match weakened that conclusion.

The Tribunal therefore held that the order suffered from non-application of mind and failure to adequately address the applicant’s representation. The finality clause in the examination notice could not validate an arbitrary or unreasoned decision.

The order was accordingly quashed and set aside. The respondents were directed to process the applicant’s case in accordance with law, restore his candidature, and permit him to join the Directorate of Plant Protection, Quarantine & Storage, subject to fulfilment of all other applicable eligibility conditions.

The applicant was also granted consequential notional benefits, including seniority, in accordance with the applicable rules and his category. The exercise was to be completed within three months from receipt of the certified copy of the order. The O.A. was allowed, with no order as to costs.