Fraudulent procurement of PSTM certificates and bogus degrees vitiates selection and justifies summary dismissal from public service.

The petitioners were provisionally selected for various Group-I civil service posts (Deputy Collector, DSP, Assistant Commissioner) under the 20% "Persons Studied in Tamil Medium" (PSTM) reservation quota

Following a Public Interest Litigation and subsequent investigation by the Vigilance and Anti-Corruption (VAC) Department, it was alleged that the petitioners obtained bogus degree certificates from Madurai Kamaraj University (MKU) without following admission procedures or paying fees

The VAC registered Crime No. 12 of 2024 against the petitioners and university officials

Consequently, the TNPSC issued show-cause notices and subsequently passed final orders cancelling the petitioners' provisional selection and appointments

The petitioners challenged these cancellations, arguing they were victims of administrative lapses by the university and study centers

1. Whether the TNPSC possessed sufficient objective material to conclude that the petitioners were ineligible for the PSTM quota and to cancel their provisional selection

2. Whether administrative action (cancellation of selection) must be deferred until the conclusion of pending criminal proceedings (Crime No. 12 of 2024)

The Court applied the Tamil Nadu Appointment on Preferential Basis in the Services under the State of Persons Studied in Tamil Medium Act, 2010 (PSTM Act), which mandates 20% reservation for genuine Tamil medium students

It relied on Clauses 12(L) and 13(h) of TNPSC Notification No. 1 of 2019, which allow for the summary rejection of candidates providing incorrect particulars or failing eligibility verification at any stage

The court applied the legal maxim Fraus et jus nunquam cohabitant (fraud and justice never dwell together)

the court cited Union of India v. Prohlad Gupta (2024) regarding fraud vitiating all solemn acts and Food Corporation of India v. Jagdish Balaram Bahira (2017), which established that selection of ineligible persons through fraud is a "fraud on the Constitution" and violates Article 14 and 16

The Court reasoned that while the petitioners held physical certificates, the underlying process—including recycled application numbers, missing answer scripts, and non-existent fee records—cast serious doubt on their genuineness

The Court rejected the argument that the petitioners should not suffer for study center lapses, noting that the cumulative irregularities pointed to a systemic manipulation rather than an isolated accounting error

It was clarified that administrative and criminal proceedings operate in distinct fields; hence, the TNPSC was not required to wait for a criminal conviction to determine eligibility

Since the selection was "provisional," the TNPSC retained the right under its "Instructions to Candidates" to verify eligibility even after appointment

The court found that once the issuing authority (MKU) informed the TNPSC that the certificates were invalid based on objective vigilance findings, the selection lost its legal foundation

The Court held that the petitioners, holding high-ranking civil service positions, failed to meet the required standards of integrity. All writ petitions were dismissed; the final orders of the TNPSC cancelling the provisional selections were upheld, the order of suspension against petitioner Swapna was affirmed, and the interim stay orders were vacated. No order as to costs