Fraudulent dual appointment in two police forces through manipulated identity and forged credentials constitutes grave misconduct justifying dismissal from service.

on

Facts

Respondent No. 1, Ranjan Kumar, was appointed as a Constable in Jharkhand Police on 18.05.2005. While posted at Dhurki Police Station, he proceeded on compensatory leave from 20.12.2007 to 23.12.2007 but failed to rejoin duty thereafter. During this period, he allegedly secured another appointment as Constable in Bihar Police under the name “Santosh Kumar”, son of Kamta Sharma, using different certificates and credentials.

An enquiry initiated by Bihar authorities revealed that “Ranjan Kumar” and “Santosh Kumar” were allegedly the same person. Consequently, departmental proceedings were initiated against him by the Jharkhand Police. After enquiry, the disciplinary authority dismissed him from service on 20.08.2010. His statutory appeal and memorial petition were also rejected.

The learned Single Judge upheld the dismissal. However, the Division Bench in LPA quashed the dismissal on the ground that there was no legally admissible evidence proving dual employment or impersonation. Aggrieved thereby, the State of Jharkhand approached the Supreme Court.

Issues Framed

Whether the disciplinary action culminating in removal of Respondent No. 1 from service suffered from any legal infirmity warranting interference in judicial review. (Para 9)

Court’s Reasoning

(a) Scope of Judicial Review in Departmental Proceedings

The Court reiterated that in departmental enquiries, the standard of proof is that of “preponderance of probabilities” and not proof beyond reasonable doubt. Reliance was placed on Union of India v. Subrata Nath, B.C. Chaturvedi v. Union of India, and P. Gunasekaran. The Court observed that High Courts exercising jurisdiction under Art. 226 Const. of India cannot reappreciate evidence as appellate authorities unless findings are perverse or based on “no evidence”. (Paras 18–20)

(b) Findings Based on Relevant Material

The disciplinary authority relied on appointment forms, photographs, certificates, official communications from Bihar authorities, and enquiry reports. The Court held that all three departmental authorities had concurrently found that Respondent No. 1 secured dual appointments under different identities. These findings were “founded on relevant material” and could not be termed conjectural. (Paras 11–12)

(c) Independent Enquiry Directed by Supreme Court

Pursuant to directions issued by the Court, Bihar Police conducted a fresh enquiry. The report dated 11.04.2026 established through “fingerprint examination and photographic comparison” that “Ranjan Kumar” and “Santosh Kumar” were the same person. The Court held that this scientific material “substantially dislodges the defence of mistaken identity”. (Paras 15–16)

(d) Procedural Fairness

The Court found substantial compliance with Rule 828 of the Jharkhand Police Manual read with Appendix 49. Respondent No. 1 had been served with the chargesheet, supplied relevant materials, given opportunity to defend himself, and furnished the enquiry report. Hence, principles of natural justice stood satisfied. (Para 21)

(e) Gravity of Misconduct

The Court observed that fraud in obtaining public employment, especially in police service, strikes “at the very root of public employment”. The continuance of such an employee would erode institutional discipline and public confidence. (Paras 17, 22, 24)

Held

The Supreme Court allowed the appeal, set aside the Division Bench judgment, and restored the dismissal order passed by the disciplinary authority and affirmed by the appellate and revisional authorities. The Court also exercised powers under Art. 142 Const. of India to quash the Bihar Police appointment obtained under the name “Santosh Kumar”. Further, directions were issued for initiation of appropriate criminal proceedings in accordance with law. (Paras 23–27)


Ratio

Concurrent findings of guilt in departmental proceedings based on relevant material and satisfying principles of natural justice cannot be interfered with in judicial review merely by reappreciating evidence, particularly where misconduct involves fraud, impersonation, and forged credentials in public employment.

Case Details

Citation: 2026 INSC 466
Decided on: 8 May 2026
Case Title: The State of Jharkhand & Ors. v. Ranjan Kumar & Ors.
Court: Supreme Court of India
Bench: Justice Ahsanuddin Amanullah and Justice R. Mahadevan