Fraudulent disability certificates used for public employment are void ab initio and no hearing is required.

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

Following widespread complaints regarding irregularities in such certificates, the respondents initiated a re-verification process. 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 and subsequently cancel the appointments

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

The present writ appeals contest that dismissal, primarily on grounds of lack of opportunity of hearing and the assertion that lack of registration does not per se prove forgery

1. Whether the cancellation of appointments based on the finding of forged disability certificates is valid in the absence of a prior opportunity of hearing (Principles of Natural Justice)

2. Whether the lack of entry in the official registration records is sufficient to establish that the disability certificates were forged

The court primarily applied the doctrine that "fraud vitiates every solemn act," relying on Vishnu Vardhan @ Vishnu Pradhan v. State of U.P. and S.P. Chengalvaraya Naidu v. Jagannath, establishing that a person whose case is based on falsehood has no right to approach the court

The court also invoked the "Prejudice Case" and "Useless Formality" theories regarding natural justice as discussed in State Bank of Patiala v. S.K. Sharma, Dharampal Satyapal Limited v. Deputy Commissioner of Central Excise, and Canara Bank v. Debasis Das, which hold that relief for violation of natural justice can be refused if no prejudice is shown or if only one conclusion is possible.

The High Court observed that disability certificates cannot be legally issued without a corresponding case registration in the official records; therefore, the absence of such records was sufficient grounds for the authorities to deem the certificates forged

Regarding the alleged violation of natural justice, the Court reasoned that since fraud was established, the adherence to natural justice was not mandatory

Applying the "prejudice" test, the Court noted that the appellants failed to produce any medical prescriptions or evidence before the Single Judge or the Division Bench to prove they actually suffered from the claimed visual disability

Consequently, because the appellants could not demonstrate how a hearing would have altered the outcome, the "useless formality" theory applied, and no prejudice was found to have occurred

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