Writ Jurisdiction Under Article 226 Inadmissible for Adjudicating Disputed Questions of Fact Regarding Qualification Documents

The petitioner challenged the appointment of Respondent No. 5 as an Up-Anganwadi Worker in Gram Peerikarar, District Sheopur

The petitioner alleged that Respondent No. 5 secured the position using forged 5th and 8th-class marksheets, citing verification letters from local education authorities

Conversely, Respondent No. 5 argued that the minimum qualification was Class 5, she never submitted a Class 8 marksheet, and her Class 5 marksheet was verified as genuine

Both the Collector and the Commissioner had previously dismissed the petitioner's appeals

Following a court-ordered verification in 2025, the State confirmed the authenticity of Respondent No. 5’s Class 5 marksheet and noted the absence of any Class 8 submission

1. Whether the High Court can exercise its extraordinary jurisdiction under Article 226 of the Constitution to adjudicate matters involving hotly disputed questions of fact regarding the authenticity of documents

2. Whether the appointment of Respondent No. 5 was valid based on the verified minimum educational qualifications

The court primarily applied the settled legal principle that jurisdiction under Article 226 of the Constitution of India should not be exercised when a case involves "disputed questions of fact"

Chairman, Grid Corporation of Orissa Ltd. (GRIDCO) v. Sukamani Das, which held that actions requiring evidence and examination of circumstances are better suited for civil courts rather than writ petitions based on affidavits

Shubhas Jain v. Rajeshwari Shivam to emphasize that the High Court should not make comparative assessments of conflicting technical/verification reports

M.P. Power Management Co. Ltd. v. Sky Power Southeast Solar India (P) Ltd. regarding the existence of alternative remedies in cases requiring the resolution of factual disputes

The Court observed that the core of the dispute rested on the authenticity of educational documents, which constitutes a "disputed question of fact"

While the petitioner produced letters suggesting forgery, the official respondents submitted a verification report (Annexure R/4) and a 2025 court-ordered verification declaring Respondent No. 5's Class 5 marksheet as genuine

Since the minimum qualification for the post was Class 5, and Respondent No. 5 held a higher merit position based on that verified marksheet, the legal requirements for the appointment were met

Applying the precedents of GRIDCO and Shubhas Jain, the Court reasoned that it could not adjudicate between these conflicting factual claims in a writ proceeding and that such matters must be relegated to civil remedies

It concluded that since Respondent No. 5’s Class 5 marksheet was verified by official authorities and satisfied the eligibility criteria, her appointment was valid. The petition was dismissed as bereft of substance.