Facts: The appellant, a Court Attender, was dismissed from service following a disciplinary inquiry on two charges: unauthorized absence from 03.08.2017 to 07.08.2017 and the submission of a fabricated medical certificate. The appellant claimed he was suffering from fever and had consulted a local doctor (PW-2). During the inquiry, the doctor admitted that the appellant had consulted him and that the letterhead and rubber stamp used for the certificate were genuine. However, the doctor denied issuing the specific certificate (Ex. P-7), claiming his letterhead was stolen and the signature was fabricated. The Inquiry Officer relied solely on the doctor's oral denial to hold the charges proved, leading to the appellant's dismissal.
Procedural Posture: The appellant challenged the dismissal order before the Administrative Side of the High Court, which was rejected. Subsequently, the appellant filed a Writ Petition before the High Court for the State of Telangana. The Division Bench dismissed the petition, confirming the dismissal. The matter reached the Supreme Court via Special Leave Petition.
Issue: Whether the findings of the Inquiry Officer regarding the fabrication of the medical certificate were perverse and based on "no evidence", justifying interference under the limited scope of judicial review in disciplinary matters.
Holding: Yes. The Supreme Court set aside the dismissal and ordered the appellant's reinstatement with full consequential benefits.
Reasoning: The Court reasoned that while judicial review is limited, it is permissible to interfere when findings are perverse or based on no evidence. In this case, the doctor (PW-2) admitted treating the appellant and confirmed the letterhead and rubber stamp were his. The Inquiry Officer failed to account for the fact that the doctor's undisputed signatures on other documents were not identical to each other, yet were broadly similar to the signature on the disputed certificate. The Court held that "graver the charge – greater the need for caution and circumspection". The Inquiry Officer should have referred the handwriting to an expert or conducted a more rigorous verification before concluding forgery. Relying solely on the oral testimony of a witness whose own statements contained inherent improbabilities made the finding perverse. Since the charge of forgery was not established, the mandatory penalty of dismissal could not be sustained.