Judicial Observations Cannot Alter Document Contents; Evidentiary Rules and Competent Witness Testimony Prevail in Inquiries.

The respondent, Manish Kumar, was dismissed from his post as GDSBPM, Bansgopal, following allegations that his educational mark-sheets were fraudulent.

The Central Administrative Tribunal (CAT), Patna Bench, in O.A. No. 050/00598/2024, quashed the dismissal, appellate, and revisional orders on 12.01.2026.

The CAT directed his reinstatement but allowed the petitioners (Postal Department) to conduct a fresh inquiry by cross-examining the author of the verification reports.

The Union of India challenged this before the High Court, specifically seeking clarification on factual observations made by the CAT regarding the authenticity of documents mentioned in the written statement.

1. Whether the factual observations made by a judicial tribunal in an order can override or alter the actual contents of the evidence/documents on record.

2. Whether the writ petition should be entertained when the petitioners concede to the primary relief of the impugned order but seek clarification on observations.

The Court applied the fundamental principle of the Rules of Evidence, holding that the contents of a document must be proved on its own face value and through the examination of competent witnesses.

The principle that judicial observations cannot be used to modify the inherent content of a documentary exhibit.

The petitioners argued that the CAT made factually incorrect observations in paragraphs 7(a) and (b) regarding a letter dated 14.05.2018 from the Bihar Sanskrit Shiksha Board, which stated that the respondent's mark-sheet was not issued by the Board.

The High Court reasoned that since the petitioners no longer intended to challenge the quashing of the dismissal order itself, the primary concern was the evidentiary value of the documents in the upcoming fresh inquiry.

The Court determined that a judicial observation does not possess the power to alter the text of a document.

It clarified that the Inquiry Officer is duty-bound to consider the documents' "face value" and ensure they are proved by a competent witness during the de novo proceedings as per the CAT's directions.

Consequently, the writ petition was disposed of as "not pressed," effectively upholding the CAT's direction for reinstatement and a fresh inquiry, while clarifying that the petitioners are free to prove the alleged forgery through proper examination of witnesses.