CAT - ['Chandigarh']
Employment and Labour LawAdministrative and Public Law

Biometric mismatch corroborated by expert evidence permits candidature cancellation without mandatory re-verification.

Krishan vs Gm N.rly.

CAT - ['Chandigarh']JUDGMENT: August 13, 20263 MIN READSOURCE JUDGMENT
Biometric mismatch corroborated by expert evidence permits candidature cancellation without mandatory re-verification.. Krishan vs Gm N.rly.. CAT - ['Chandigarh']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant applied under the unreserved category pursuant to Employment Notification/CEN No. 02/2018 for recruitment to Group-D/Level-1 posts in the Railways. He possessed the requisite educational qualification, cleared the Computer Based Test (CBT), qualified the Physical Efficiency Test (PET), and appeared for Document Verification (DV).

Source reference: paras. 2–3

During DV, his biometric verification could not be completed and he was subsequently informed that his candidature had been rejected because the biometric data obtained during the CBT did not match the impressions recorded during the PET and DV.

Source reference: paras. 3–4

The respondents stated that the discrepancy was considered by a Standing Committee and was thereafter confirmed by the Government Chief Finger Print Expert. They also relied on alleged discrepancies in the applicant’s handwriting and signatures at different stages, contending that the material established impersonation.

Source reference: paras. 6–13

The applicant sought quashing of the rejection and an opportunity for re-verification through alternative identification methods, relying, inter alia, on Veena Yadav & Ors. v. State of Haryana & Ors.

Source reference: para. 5
02

Issues

1. Whether the rejection of the applicant’s candidature on the basis of biometric mismatch, supported by handwriting and signature discrepancies, was arbitrary, illegal, or unsupported by evidence.

Source reference: para. 14

2. Whether the applicant was entitled to re-verification of his identity through alternative methods such as photographs, signatures, handwriting, or videography before cancellation of his candidature.

Source reference: paras. 21–23

3. Whether the applicant was entitled to any direction for reservation of an advertised unreserved post pending adjudication of the Original Application.

Source reference: para. 25
03

Law Applied

The Tribunal exercised jurisdiction under Section 19 of the Administrative Tribunals Act, 1985.

Source reference: para. 1

It applied the conditions of CEN No. 02/2018, under which candidature remained provisional throughout the recruitment process and could be cancelled at any stage upon detection of ineligibility, discrepancy, or impersonation; mere participation in the CBT, PET, or DV did not create an indefeasible right to appointment.

Source reference: paras. 6, 15, 23

The Tribunal further applied the principle that judicial review does not permit an appellate re-assessment of specialised expert evidence and that interference is warranted only where the decision is perverse, arbitrary, mala fide, or based on no material.

Source reference: para. 24

The principle in Veena Yadav & Ors. v. State of Haryana & Ors. , concerning re-verification through alternative identification methods in cases of biometric difficulty, was held to be fact-specific and not to create an automatic right to re-verification in every case.

Source reference: para. 22
04

Reasoning

The Tribunal held that the applicant’s candidature was provisional and subject to identity verification at every stage.

Source reference: para. 15

The rejection was not based merely on an automated failure of biometric authentication or a subjective Standing Committee assessment. The Government Chief Finger Print Expert specifically compared the thumb impressions from the CBT, PET, and DV stages and opined that the CBT impression did not tally with the later impressions.

Source reference: paras. 16–18

This expert opinion was additionally corroborated by material discrepancies in the applicant’s handwriting and signatures.

Source reference: para. 19

As the applicant produced no contrary expert evidence or material demonstrating that the reports were scientifically unreliable, the Tribunal found a reasonable and objective basis for the conclusion of impersonation.

Source reference: paras. 18–20

It further held that CEN No. 02/2018 did not confer a right to a second verification or require a separate show-cause notice where material identity discrepancies had been detected during the prescribed verification process.

Source reference: paras. 21–23

The decision in Veena Yadav was distinguishable because the present case involved corroborative expert and documentary material beyond a mere biometric failure.

Source reference: para. 22
05

Holding

The Tribunal answered the principal issues against the applicant. It held that the cancellation of his candidature was neither arbitrary nor unsupported by evidence, and that he had no enforceable right to re-verification through alternative identification methods.

The Original Application was dismissed, the prayer for reservation of one unreserved post was rejected as consequentially unsustainable, and any pending miscellaneous applications were disposed of. No order as to costs was made.

Source reference: para. 25
CAT - ['Chandigarh']

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KrishanvsGm N.rly.

CAT - ['Chandigarh'] · August 13, 2026

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