Documentary evidence must be evaluated on its own face value and proved through competent witnesses during disciplinary inquiries.

The petitioners (Department of Posts) challenged an order dated 12.12.2025 passed by the Central Administrative Tribunal (CAT), Patna Bench.

The CAT had quashed the dismissal, appellate, and revisional orders against the respondent, Mantu Kumar (a GDSMD), on the grounds of procedural irregularities in the inquiry regarding his mark-sheets.

The CAT ordered his reinstatement and granted the petitioners liberty to complete a fresh inquiry by allowing the respondent to cross-examine the signatory of the verification document.

During the High Court proceedings, the petitioners chose not to contest the CAT's order but sought clarification regarding certain factual observations made by the CAT in paragraphs 7(a) & (b) concerning the verification of the respondent's mark-sheets by the Bihar Sanskrit Shiksha Board.

1. Whether the observations made by the Central Administrative Tribunal regarding the factual contents of a document can bind the Inquiry Officer or supersede the document’s face value.

2. Whether the writ petition should be entertained given the petitioners’ concession not to assail the primary directions of the CAT.

Statement identifying a key statute, principle, or precedent: The Court applied the principle of the "best evidence rule" and the finality of documentary evidence, holding that the contents of a document cannot be altered or superseded by judicial observations.

Such documents must be considered on their own "face value" and must be proved by "examining a competent witness by adhering to the rules of evidence".

The Court noted that the petitioners did not intend to challenge the quashing of the dismissal or the order for reinstatement. Their grievance was limited to potential factual inaccuracies in the CAT’s order regarding a letter dated 14.05.2018 from the Bihar Sanskrit Shiksha Board, which purportedly stated the respondent's mark-sheets were not issued by the Board.

The High Court reasoned that a judicial observation cannot change the inherent contents of a document. Consequently, during the de novo inquiry permitted by the CAT, the Inquiry Officer is duty-bound to evaluate the evidence independently. The Court emphasized that for the document to hold weight in a disciplinary proceeding, it must be proved through proper examination of witnesses rather than relying on summary observations in a judgment.

The High Court disposed of the writ petition as "not pressed". The CAT's directions to reinstate the respondent and allow a fresh inquiry with the right to cross-examine relevant witnesses remain intact.