Documentary evidence must be considered on its face value and proved through competent witnesses.

The petitioners (Postal Department) challenged an order dated 12.01.2026 passed by the Central Administrative Tribunal (CAT), Patna Bench, which had quashed the dismissal, appellate, and revisional orders against the respondent, a GDS Packer

The respondent was dismissed following allegations that his mark-sheets were not issued by the Bihar Sanskrit Shiksha Board

The CAT set aside the dismissal and ordered reinstatement with the liberty to conduct a fresh inquiry by cross-examining the author of the verification documents

During the writ proceedings, the petitioners chose not to contest the CAT's primary order but sought clarification regarding certain factual observations made by the CAT in paragraphs 7(a) & (b) concerning the verification reports from the Board

1. Whether the observations made by a judicial tribunal in an order can override or alter the actual contents of an underlying documentary evidence during a subsequent inquiry?

The court applied the fundamental principle of the Law of Evidence and Administrative Jurisprudence that the contents of a document must be considered on their own face value and cannot be altered by judicial observations

Furthermore, in departmental inquiries, charges must be proved by adhering to the rules of evidence, specifically through the examination of competent witnesses to prove the authenticity and contents of mentioned documents

The High Court noted the petitioners' concern that the CAT had made factually incorrect observations regarding the Board's verification letters dated 05.10.2016 and 14.05.2018

the Court reasoned that a judicial order's commentary on a document does not legally modify the document itself

It held that the Inquiry Officer is duty-bound to evaluate the evidence—specifically the letter stating the respondent's mark-sheet was not issued by the Board—on its own merits

To ensure a fair trial as directed by the CAT, the document must be proved by examining a competent witness, allowing the respondent an opportunity for cross-examination, rather than relying on the CAT’s summary of the facts

It clarified that the contents of the verification documents must be considered on their face value by the Inquiry Officer and proved via competent witnesses, regardless of the CAT's observations

The CAT's directions to reinstate the respondent and the liberty granted to the petitioners to complete the inquiry with modified witness lists remain intact