Fraud Vitiates Appointments; Breach of Natural Justice Claims Fail Absent Proof of Prejudice or Authenticity

The appellants were appointed as Primary Teachers under the visual disability category based on disability certificates supposedly issued by the Medical Board

It was discovered that the registration and case numbers for the appellants' certificates were absent from the official filing registers, leading the authorities to conclude the documents were forged

The appellants challenged these cancellations via writ petitions, which were dismissed by a learned Single Judge on 19.08.2025

The appellants then filed these writ appeals, contending that the absence of registration does not equate to forgery and that they were denied an opportunity for a hearing

1. Whether the cancellation of appointments based on forged disability certificates was valid despite the alleged lack of a formal hearing

2. Whether the "useless formality theory" and the principle that "fraud vitiates every solemn act" apply to dispense with the principles of natural justice in this context

The court applied the fundamental legal maxim fraus et jus nunquam cohabitant (fraud and justice never dwell together) and the principle that "fraud vitiates every solemn act," rendering any benefit obtained through it a nullity

It relied on Vishnu Vardhan v. State of U.P. [2025 SCC OnLine SC 1501] and S.P. Chengalvaraya Naidu v. Jagannath [(1994) 1 SCC 1] to establish that a person whose case is based on falsehood has no right to approach the court

The court further applied the "prejudice" and "useless formality" doctrines from State Bank of Patiala v. S.K. Sharma [(1996) 3 SCC 364] and Dharampal Satyapal Ltd. v. Commissioner of Central Excise [(2015) 8 SCC 519], which dictate that an order will not be quashed for a violation of natural justice unless the aggrieved party demonstrates actual prejudice

The Court reasoned that once it was established that the disability certificates lacked corresponding entry numbers in the official registers, the conclusion of forgery was justified

Regarding the violation of natural justice, the Court observed that fraud unravels all transactions and prevents the fraudster from claiming technical protections

The Court noted that even during the appeal, the appellants failed to produce any medical prescriptions or evidence to substantiate their claim of visual disability

Given the "admitted and indisputable" nature of the fraud—where the certificates were proved false by a verification committee—the Court held that a personal hearing would be a "useless formality" as it would not change the outcome

Since no prejudice was shown by the appellants, the requirement for a pre-termination hearing was waived

The Court concluded that fraud vitiates the appointments ab initio and the principles of natural justice cannot be used to protect illegal gains derived from forgery

The Court dismissed all writ appeals, vacated all interim orders, and directed the appellants to immediately cease functioning as Primary Teachers