In K. Rajaiah v. High Court for the State of Telangana
(2026)
The Supreme Court of India in K. Rajaiah v. High Court for the State of Telangana (Civil Appeal No. 1560 of 2026, decided on 11 February 2026) has delivered a significant ruling on the scope of judicial review in disciplinary proceedings, particularly where grave allegations such as forgery are levelled. The appellant, a court attender appointed in 1998, was dismissed from service on the charge of fabricating a medical certificate to justify a brief period of absence in August 2017. While the disciplinary authority found both unauthorized absence and submission of a fabricated certificate proved, the Supreme Court, exercising limited judicial review, found the core finding of forgery to be unsupported by credible evidence. The Court emphasized that although departmental enquiries are not criminal trials, findings must nevertheless rest on cogent material. Where the charge is serious and entails mandatory dismissal under service rules, the evidentiary threshold demands greater caution and circumspection.
The controversy revolved around a handwritten medical certificate allegedly issued by a private practitioner. The doctor admitted that the employee had consulted him and received medication, acknowledged that the letterhead and rubber stamp on the certificate belonged to him, but denied issuing the certificate and alleged fabrication. Crucially, the Inquiry Officer accepted the doctor’s denial without comparing the disputed signature with admitted signatures or referring the matter to a handwriting expert. The Supreme Court found this omission fatal. Observing that the certificate was entirely handwritten and that even the doctor’s admitted signatures were not identical, the Court held that prudence required expert verification before recording a finding of forgery. Reliance was placed on precedents including Sawai Singh v. State of Rajasthan, reiterating that disciplinary findings unsupported by reliable evidence or marked by perversity are amenable to interference. The Court further noted procedural peculiarities, including the recording of a preliminary statement behind the employee’s back and the reopening of proceedings after initial closure, which cast doubt on the fairness of the process.
Reaffirming settled principles governing judicial review of disciplinary action, the Court clarified that while writ courts do not act as appellate forums, interference is warranted where findings are based on no evidence or where no reasonable person could have arrived at such conclusions. The allegation of forgery, carrying mandatory dismissal under the applicable Conduct Rules, required strict scrutiny. In the absence of expert comparison or conclusive proof, the charge was held unproved and the findings termed perverse. Consequently, the dismissal order and the appellate confirmation were set aside, and reinstatement with full consequential benefits was directed. This Supreme Court ruling reinforces doctrinal clarity on evidentiary standards in service jurisprudence and underscores that proportionality and procedural fairness remain central even within the limited contours of judicial review in disciplinary matters.
