Patna High Court

Secondary matriculation certificate obtained for improving marks is invalid for appointment if a prior certificate exists.

Kumari Jayanti Sinha v. The State of Bihar & Ors. [CWJC No. 9583 of 2024]

Patna High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was selected as an Anganwadi Sevika on October 13, 2017, and joined service on October 15, 2017

Source reference: p. 2

Following a complaint, the District Programme Officer (DPO), in Anganwadi Appeal Case No. 56/2017, cancelled her selection on August 28, 2019, directing the appointment of respondent no. 8 in her place

Source reference: p. 3

The petitioner’s subsequent appeal (No. 10/2019-20) before the Collector-cum-District Magistrate, Patna, was rejected on June 14, 2023

Source reference: p. 3

The authorities found that the petitioner had obtained a matriculation certificate in 1994 from the Bihar School Examination Board and a second matriculation certificate in 2014 from the Bihar Sanskrit Education Board to improve her marks for selection

Source reference: p. 5

Discrepancies were also noted in the date of birth recorded across her Aadhaar and Voter ID cards

Source reference: p. 6
02

Issues

Whether the selection of a candidate based on a second matriculation certificate obtained for the purpose of improving marks/results is legally valid when a prior certificate for the same degree exists.

Source reference: p. 5/6

Whether the orders passed by the DPO and the Collector-cum-District Magistrate cancelling the petitioner’s appointment suffer from any legal infirmity.

Source reference: p. 6
03

Law Applied

The Court applied the legal principle established in Amarjeet Singh Rathaur v. The State of Bihar & Ors. (CWJC No. 13190 of 2009), which stipulates that when an individual possesses two certificates for the same degree, only the first certificate shall be recognized for official purposes, and the second certificate cannot be used to secure employment or any other service benefits

Source reference: p. 5, 6
04

Reasoning

The Court observed that the petitioner’s claim of following the 2016 appointment guidelines was undermined by the suppression of her 1994 matriculation qualification

Source reference: p. 5

The Court found that the petitioner appeared for the 2014 examination solely to improve her marks to gain an unfair advantage in the selection process for Anganwadi Sevika

Source reference: p. 5

Relying on the precedent in Amarjeet Singh Rathaur, the Court reasoned that the second certificate was legally void for the purpose of appointment

Source reference: p. 6

Furthermore, the Court noted that the Collector had recorded specific findings regarding discrepancies in the petitioner's date of birth across various identification documents, which further invalidated her candidacy

Source reference: p. 6
05

Holding

The Court answered the issues in the negative, holding that the writ petition lacked merit due to the petitioner’s reliance on an impermissible second certificate and the suppression of facts

The High Court upheld the orders of the DPO and the District Magistrate, Patna, which cancelled the petitioner's selection and appointed respondent no. 8

Source reference: p. 6

The writ petition was dismissed

Source reference: p. 6
Patna High Court

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Kumari Jayanti Sinha v. The State of Bihar & Ors. [CWJC No. 9583 of 2024]

Patna High Court · no citation

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