A verified qualification certificate cannot be rejected as forged on mere suspicion.

The petitioner challenged the Collector, District Bhind’s order dated 30 April 2014 cancelling his candidature for appointment as Patwari because his PGDCA certificate was considered doubtful. He sought quashing of the order and a direction for appointment

In the companion matter, *Vandana Soni v. State of Madhya Pradesh and Others*, the Court considered the grounds underlying the cancellation, including the status of the issuing university and difficulties in verification by another university

The issuing university subsequently confirmed that the certificates of the candidates named in its communication—including Arun Kumar Majhi—were genuine and that their names appeared in its records

The Court disposed of this petition by applying the directions in *Vandana Soni* *mutatis mutandis*

1. Whether the petitioner’s candidature could be cancelled as doubtful or forged on the grounds recorded by the Collector, particularly after the issuing university verified his certificate as genuine

2. Whether cancellation on an allegation of a forged educational certificate could be sustained without the procedure required by law

Under *Prof. Yashpal v. State of Chhattisgarh*, (2005) 5 SCC 420, the invalidation of the statutory framework for private universities did not, by itself, establish that every certificate issued before the judgment was forged; genuineness and recruitment validity are distinct questions to be assessed on relevant material

*Ved Prakash Sharma v. State of M.P.*, 2011 (3) MPLJ 148, required examination of the relevant certificates in accordance with law

The Court also relied on *Anoop Jaiswal v. Government of India*, (1984) 2 SCC 369, concerning scrutiny of the real basis and effect of an adverse order, and *Punjab State Electricity Board v. Leela Singh*, (2007) 12 SCC 146, for the principle that an allegation of obtaining appointment through a forged certificate must be established through a duly constituted proceeding

The incorporated reasoning further held that a stigmatic, punitive action founded on alleged misconduct must comply with the applicable Madhya Pradesh Civil Services (Classification, Control and Appeal) Rules, 1966 and, where applicable, Article 311(2) of the Constitution

The Court adopted the reasoning in *Vandana Soni*.

That reasoning found that the Collector’s stated concerns—including the university’s subsequent closure, another university’s inability to verify records, an earlier certificate from another institution, the timing of the examination and the absence of transferred students—did not establish forgery

The issuing university’s later confirmation that the certificates were genuine and the candidates’ names appeared in its records directly addressed those doubts

The Court further accepted that an administrative verification could not substitute for the procedure required to establish a serious allegation of forgery where the action was punitive and stigmatic

Finding the controversy in this petition covered by the companion decision, it applied that decision’s directions to the petitioner

Accordingly, the Collector’s cancellation order was quashed, and the respondents were directed to appoint the petitioner as Patwari in accordance with law and grant consequential benefits, excluding back wages on the principle of “No Work, No Pay.”

The respondents may take action in accordance with law if the concerned university or society declares the certificate forged; the directions are to be completed within three months of receiving a certified copy of the order.