Patna High Court upholds disqualification of 146 Junior Engineer candidates over doubtful SRK University diploma records

The petitioners in the principal and analogous writ petitions either sought consideration for appointment as Junior Engineers pursuant to Bihar Technical Service Commission Advertisement No. 01/2019, or challenged consequential termination from contractual service. Most petitioners held Diploma in Civil Engineering certificates issued by Sarvepalli Radhakrishnan University, Bhopal (“SRK University”).

Their applications were initially accepted, and several petitioners were included in the earlier merit list dated 02.04.2022 or were called for document verification. Following the Supreme Court’s decision in Shashi Bhushan Prasad v. State of Bihar, SLP (C) No. 7257 of 2023, decided on 04.10.2024, the BTSC undertook fresh verification pursuant to the revised selection process.

A joint verification conducted by officials revealed alleged discrepancies in the certificates and mark-sheets, including inconsistent serial-number series for documents issued on the same date and in the same session, varying signatures and seals, inconsistent references to CGPA, percentage and lateral entry, spelling errors, and, in one case, two certificates bearing the same issue number but accompanied by different mark-sheets.

By Memo No. 3892 dated 20.12.2024, the BTSC declared the candidature of 146 candidates holding such diplomas invalid and excluded them from the revised/final merit list.

In CWJC No. 8568 of 2024, the petitioner separately challenged termination from contractual service; the University had specifically stated that the certificate relied upon by him had not been issued by it.

1. Whether the BTSC was justified in treating the Diploma in Civil Engineering certificates and mark-sheets issued by SRK University as doubtful and in disqualifying the concerned candidates from the recruitment process on the basis of the discovered discrepancies?

2. Whether a recruiting body is required to await a criminal investigation, forensic examination, or a formal cancellation of the certificates by the University or regulatory authority before excluding candidates whose educational credentials are surrounded by substantial suspicion?

3. Whether the termination of the petitioner in CWJC No. 8568 of 2024 was sustainable where SRK University expressly denied issuing the certificate relied upon by him?

4. Whether the petitioners were entitled to inclusion in the revised merit list and appointment pursuant to Advertisement No. 01/2019 and the Supreme Court’s directions dated 04.10.2024?

The Court applied the preponderance-of-probabilities standard for assessing the genuineness of educational certificates, holding that a recruiting body need not establish forgery beyond reasonable doubt before protecting the integrity of a public recruitment process.

It further held that a public recruiting agency may exclude candidates where material discrepancies substantially undermine the authenticity of the qualifications required for appointment.

The Court also relied on the Supreme Court’s directions in Shashi Bhushan Prasad v. State of Bihar, SLP (C) No. 7257 of 2023, decided on 04.10.2024, requiring preparation of a fresh select list after applying the High Court’s institutional-reservation directions and, as far as possible, including otherwise eligible candidates excluded solely under the earlier regulatory framework.

The Court followed its earlier decisions in Manohar Manjhi v. State of Bihar, CWJC No. 4102 of 2025, and Prince Raj v. State of Bihar, CWJC No. 5733 of 2025, which declined interference where the recruiting authority had recorded specific grounds casting doubt on the genuineness of educational credentials.

In the termination matter, the Court applied the University’s express denial that the certificate had been issued by it, together with the contractual condition permitting termination where qualification documents were found incorrect.

The Court held that the discrepancies were not isolated clerical variations but formed a cumulative evidentiary pattern affecting the reliability of the certificates and mark-sheets. The differing serial-number series for documents allegedly issued on the same date and session, inconsistent issuing signatures and seals, variations concerning lateral entry and grade formats, and the existence of duplicate certificates with the same issue number created a substantial and objectively reasonable doubt regarding authenticity.

The Court also considered the alleged mismatch between sanctioned intake and the number and distribution of candidates claiming diplomas from the University as corroborative circumstances.

Although the Court acknowledged that it could not conclusively determine, beyond reasonable doubt, whether each document was forged, it found that such a standard was unnecessary at the recruitment stage. The BTSC was entitled, and indeed obliged, to prevent doubtful qualifications from being used to secure public employment on the basis of the preponderance of probabilities.

In CWJC No. 8568 of 2024, the University’s specific denial that the petitioner’s certificate had been issued by it conclusively undermined his claim to continued contractual employment.

Consequently, the Court found no legal basis to direct publication of the petitioners’ results, inclusion in the merit list, or appointment.

It held that the Commission was not required to await criminal proceedings, forensic verification, or formal cancellation of the certificates before taking protective action in the recruitment process.

The termination challenged in CWJC No. 8568 of 2024 was also sustained because SRK University denied issuing the petitioner’s certificate.

Accordingly, all twelve writ petitions were dismissed, with no direction for publication of results, inclusion in the revised merit list, appointment, or restoration of contractual service.