Authenticity of Educational Qualifications Confirmed by Official Verification Supersedes Allegations of Forgery in Appointment Disputes

The petitioner challenged the appointment of Respondent No. 6 as an Anganwadi Worker at Mini Anganwadi Kendra Khairaha, District Sidhi

The petitioner alleged that Respondent No. 6 forged her Class 5th marksheet by overwriting "114" to "124" marks to artificially inflate her percentage from 57% to 62%

Initially, the Collector (Respondent No. 3) allowed the petitioner's appeal on 18.04.2012, quashing Respondent No. 6's appointment after finding evidence of overwriting

However, the Additional Commissioner (Respondent No. 2) reversed this decision on 01.06.2016, holding that even with 114 marks, Respondent No. 6 remained more meritorious

During the writ proceedings, the High Court directed the District Education Officer to verify the original records, who subsequently confirmed the validity of the marksheet in a report dated 17.11.2022

1. Whether the selection of Respondent No. 6 was vitiated by the submission of a forged marksheet

2. Whether the Additional Commissioner erred in quashing the Collector's order and affirming the merit-based selection of Respondent No. 6

The Court applied the principles of Article 226 of the Constitution of India regarding the scope of judicial review in administrative appointments

The core legal principle relied upon was that merit is the paramount consideration for public appointments, and a selection should not be disturbed if the candidate's merit position is legitimately higher than the challenger’s

The Court also highlighted the principle of administrative finality based on factual verification by competent authorities (such as the District Education Officer)

The Court examined the conflicting findings of the Collector and the Additional Commissioner. It noted that the Additional Commissioner’s order did not rely on the alleged forged score of 124 marks, but rather calculated the merit based on the original 114 marks

Upon adding BPL (Below Poverty Line) points and weightage for higher education, the Court observed that Respondent No. 6 secured 58.5 marks compared to the petitioner's 50 marks

Crucially, the Court relied on the compliance report submitted by the District Education Officer on 17.11.2022, which verified the official records and found the marksheet of Respondent No. 6 to be correct, thereby neutralizing the allegation of forgery

Consequently, the Court found the Additional Commissioner’s reasoning to be objective and supported by the record, rather than mechanical

The High Court dismissed the writ petition and affirmed the order dated 01.06.2016 passed by the Additional Commissioner, Rewa Division, confirming the appointment of Respondent No. 6