An issuing university’s confirmation of genuineness defeats cancellation based solely on suspected certificate forgery.

The petitioner appeared in the 2008 Patwari Selection Examination, scored 87.16 marks and was placed on the waiting list in the OBC Women category.

Her candidature was cancelled by the Collector, Bhind, on 30 April 2014, because her PGDCA certificate from the erstwhile University of Technology and Sciences, Raipur, was considered doubtful.

The petitioner had completed Patwari training but was not appointed.

During the proceedings, the issuing University confirmed by communication dated 5 February 2026 that the certificate was genuine and that the petitioner’s name appeared in its records.

The petitioner sought quashing of the cancellation order and appointment as Patwari.

Whether the respondents were justified in cancelling the petitioner’s candidature on the stated grounds, particularly after the issuing University verified her certificate as genuine.

Whether the petitioner’s candidature could be cancelled on an allegation of forgery without establishing that allegation through the procedure required by law.

The Court relied on Prof. Yashpal v. State of Chhattisgarh, (2005) 5 SCC 420, to distinguish the invalidation of private universities from proof that every certificate issued by them was forged; genuineness and recruitment validity are separate questions requiring examination on the relevant material.

It referred to Ved Prakash Sharma v. State of M.P., 2011 (3) MPLJ 148, on examination of computer-qualification certificates in light of Prof. Yashpal.

Relying on Anoop Jaiswal v. Government of India, (1984) 2 SCC 369, and Punjab State Electricity Board v. Leela Singh, (2007) 12 SCC 146, the Court stated that the true basis of an adverse order may be examined and that an allegation of fraud or forgery carrying serious consequences must be established through proper proceedings.

The Court also discussed Article 311(2) of the Constitution and the Madhya Pradesh Civil Services (Classification, Control and Appeal) Rules, 1966, as requiring due process where stigmatic punitive action is taken.

The Collector’s five grounds—Prof. Yashpal, lack of records at Pandit Ravishankar Shukla University, the petitioner’s earlier certificate from another institution, the timing of the examination and result, and the absence of DCA/PGDCA students among later-affiliated students—did not establish that the petitioner’s certificate was forged.

The issuing University’s later confirmation of genuineness and the presence of the petitioner’s name in its records directly addressed the doubts underlying the cancellation.

The Court further held that an administrative verification could not, by itself, conclusively establish forgery or justify a stigmatic adverse action without the legally required procedure.

It distinguished State of M.P. v. Sher Singh Rawat because the record did not show that the petitioner had obtained her qualification through an unauthorised study centre of the kind considered there.

It directed the respondents to appoint her as Patwari in accordance with law and grant consequential benefits, excluding back wages on the principle of “No Work, No Pay”.

The respondents were barred from treating the certificate as forged solely on the five grounds in the impugned order, but remained at liberty to act in accordance with law if the concerned University or Society declares it forged.

The exercise was to be completed within three months of receipt of a certified copy of the order.