Judicial observations cannot alter the contents of a documentary record which must be proved by evidence.

The respondent, Chandra Bhushan Kumar, was dismissed from his post as GDSBPM, Itahari, following allegations that his mark-sheets were not issued by the Bihar Sanskrit Shiksha Board.

The Central Administrative Tribunal (CAT), Patna Bench, quashed the dismissal, appellate, and revisional orders on 16.12.2025, directing the respondent’s reinstatement and granting the petitioners liberty to conduct a fresh inquiry with the right of cross-examination for the respondent.

The Union of India moved the High Court not to set aside the CAT’s order, but to seek clarification regarding certain factual observations made by the CAT in Paragraph 6(a) and (b) concerning letters exchanged between the Postal Department and the Education Board in 2016 and 2018.

1. Whether judicial observations regarding the contents of a sub-judice document can override the actual face value of the document during a departmental inquiry.

2. Whether the writ petition should be entertained when the petitioners do not intend to assail the core findings of the CAT's order.

The court applied the principle of the "best evidence rule" and the independence of departmental inquiries, holding that the contents of a legal document cannot be altered by judicial observations and must be proved on their own face value through competent witnesses.

It adhered to procedural law regarding the disposal of petitions as "not pressed" when the primary relief is no longer sought.

The Court examined the petitioners’ concern that the CAT had made factually incorrect observations regarding a letter dated 14.05.2018 from the Examination Controller, Bihar Sanskrit Shiksha Board, which purportedly stated that the respondent's mark-sheet was not issued by the Board.

The Court reasoned that a judicial order's observation cannot modify the inherent content of a documentary exhibit.

It clarified that during the fresh inquiry permitted by the CAT, the Inquiry Officer is duty-bound to consider documents based on their actual text and the evidence provided by witnesses, rather than being bound by the CAT’s summary of those facts.

Since the Union of India accepted the reinstatement and inquiry directions and only sought this clarification, the Court found no reason to interfere with the CAT's substantive judgment.

It held that the documents in question must be considered on their own face value by the Inquiry Officer and proved by examining competent witnesses according to the rules of evidence, regardless of the CAT's prior observations.