A seven-year examination debarment cannot rest solely on matching photographs without proof of impersonation.

The applicant, a candidate for the MTS and Havaldar Examination, 2022, was allotted a roll number after applying to the Staff Selection Commission (SSC).

The SSC alleged that his application photograph matched photographs submitted by candidates under other registration numbers and issued him a show-cause notice dated 23 December 2023 by email, with an SMS also stated to have been sent.

The applicant denied receiving the notice and did not submit a reply.

He challenged his seven-year debarment, which appeared in SSC debarred-candidate lists, and sought its revocation and restoration of his eligibility.

The respondents defended the action; both parties’ counsel accepted that the issue was identical to that decided in Aryan v. Union of India & Others, O.A. No. 1403/2025, on 28 April 2026.

1. Whether the applicant’s seven-year debarment, based on an alleged photograph match between separate applications, was sustainable in law.

2. Whether the Tribunal should follow the coordinate Bench decision in Aryan where the parties agreed that the issue was identical.

Section 19 of the Administrative Tribunals Act, 1985, provides the basis for the application before the Tribunal.

Clause 20.1 of the examination notice provides for cancellation of candidature and seven-year debarment in cases of impersonation or other malpractice.

The Tribunal relied on the principles set out in the coordinate Bench’s decision: a serious debarment carrying civil consequences must be supported by a fair process, cogent material, and a reasoned decision; a general allegation or uncorroborated suspicion is insufficient.

The reproduced reasoning cited, among other authorities, Gorkha Security Services v. Government (NCT of Delhi) on notice and the consequences of blacklisting, UMC Technologies Pvt. Ltd. v. Food Corporation of India on specifying the proposed action in a show-cause notice, and Kranti Associates Pvt. Ltd. v. Masood Ahmed Khan on the requirement to give reasons.

The present Bench’s operative reasoning was that it saw no reason to depart from the coordinate Bench’s decision on an issue accepted by both sides as identical.

The allegation against the applicant rested on the asserted match between his photograph and photographs in other applications.

The applicant disputed receipt of the show-cause notice, while the respondents’ case, as described in the order, was that notice had been sent by email and SMS.

The Tribunal did not separately re-examine the evidence or make independent findings on service or the photograph analysis.

Instead, because counsel for both parties agreed that the matter was identical to Aryan, the Bench adopted that decision’s reasoning, which held that a photograph match, without corroboration or proof of actual impersonation or other examination malpractice, could not sustain a seven-year debarment.

No order as to costs was made.