CAT - ['Allahabad']

Cancellation of Candidature Based Solely on Biometric Mismatch Without Expert Verification Violates Principles of Natural Justice

D K PANDEY vs Railway Recruitment Cell

CAT - ['Allahabad']JUDGMENT: April 21, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant applied for Group ‘D’ posts under Employment Notice No. 01/2013 issued by the North Central Railway

Source reference: p. 2

He successfully cleared the written examination and the Physical Efficiency Test (PET)

Source reference: p. 2

the respondents issued a show-cause notice on 27.01.2016 alleging a mismatch in his thumb impressions recorded during different stages of the recruitment process

Source reference: p. 2

Despite the applicant’s denial and request for verification, the respondents issued an order on 02.05.2016 cancelling his candidature and debarring him for life from RRC/RRB examinations on grounds of impersonation

Source reference: p. 2, 4

The applicant challenged this order, asserting that his handwriting, signature, and photographs remained undisputed and that no scientific verification was conducted before the debarment

Source reference: p. 3
02

Issues

1. Whether the cancellation of candidature and lifetime debarment based solely on an alleged thumb impression mismatch, without expert scientific validation, is legally sustainable

Source reference: p. 4-5

2. Whether the impugned action of the respondents violated the principles of natural justice and Articles 14 and 16 of the Constitution of India

Source reference: p. 3, 5
03

Law Applied

The Tribunal primarily applied the principles of natural justice and the constitutional guarantees under Articles 14 and 16 regarding fair treatment in public employment

Source reference: p. 3, 5

It relied on the precedent set by the Hon’ble High Court in Ran Vijay Singh vs. State of U.P. & Others (Writ A No. 2813 of 2017), which established that forensic/expert opinions are necessary to prove impersonation and that administrative actions based on mere suspicion of biometric mismatch without following natural justice are violative of Article 14

Source reference: p. 5
04

Reasoning

The Tribunal observed that the sole basis for the harsh penalty of lifetime debarment was the alleged mismatch of thumb impressions between the written exam and the PET

Source reference: p. 4-5

the respondents admitted that the applicant’s other identification markers—handwriting, signature, and photograph—did not show any discrepancies

Source reference: p. 5

The Tribunal reasoned that a thumb impression mismatch could occur due to technical defects or environmental factors and cannot be treated as conclusive proof of impersonation without a corroborative expert opinion

Source reference: p. 6

By failing to obtain a report from a government laboratory or biometric expert, the respondents acted arbitrarily

Source reference: p. 5-6

The Tribunal concluded that the summary cancellation of candidature without scientific verification or a reasoned inquiry constituted a gross violation of the principles of natural justice

Source reference: p. 5
05

Holding

The court held that the debarment was unsustainable due to procedural lapses and lack of evidence

The Tribunal allowed the Original Application and quashed the impugned order dated 02.05.2016. The respondents were directed to reconsider the applicant’s case by undertaking a proper verification process, including obtaining an independent expert opinion on the thumb impressions, within four months. The final outcome must be communicated via a reasoned and speaking order

Source reference: p. 6
CAT - ['Allahabad']

Original Court PDF

D K PANDEYvsRailway Recruitment Cell

CAT - ['Allahabad'] · April 21, 2026

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