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Delhi High Court Upholds CRPF Dismissal of Constable for Submitting Bogus Matriculation Certificate, Rules Claim of ‘Bona Fide Mistake’ Unconvincing

Shivam Y.

Delhi High Court upholds CRPF’s dismissal of constable Amit Kumar for fake matric certificate, rejecting claim of bona fide error; integrity emphasized. - Amit Kumar vs Union of India & Others

Delhi High Court Upholds CRPF Dismissal of Constable for Submitting Bogus Matriculation Certificate, Rules Claim of ‘Bona Fide Mistake’ Unconvincing

In a detailed order dated October 15, 2025, the Delhi High Court dismissed a petition filed by Amit Kumar, an ex-Constable (Water Carrier) of the Central Reserve Police Force (CRPF), who had challenged his removal from service on grounds of submitting a fake matriculation certificate. The Division Bench, comprising Justice Subramonium Prasad and Justice Vimal Kumar Yadav, held that the petitioner's explanation of a "bona fide mistake" could not be accepted, observing that "trust is the cornerstone of service in uniformed forces."

Background

Amit Kumar was appointed to the CRPF in May 2011 after clearing all required tests - physical, written, and medical. However, during verification, the Haryana School Education Board, Bhiwani reported that his matriculation certificate was bogus. Following an internal inquiry initiated in December 2016, the Commandant of the 89th Battalion, CRPF, passed an order on March 21, 2017, removing him from service.

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His departmental appeal to the DIG, CRPF (South Zone) and subsequent revision to higher authorities were also rejected in 2017 and 2018 respectively. Kumar then moved the Delhi High Court in W.P.(C) 8474/2019, seeking reinstatement with full benefits.

The petitioner maintained that he had lost his original mark sheet during a selection rally at Bawana, Delhi, and mistakenly submitted a duplicate obtained through a relative. He claimed that except for one digit in the roll number and a difference in total marks, all other details - name, date of birth, parentage - were correct. "I never intended to cheat; it was a genuine mix-up," his counsel argued.

Court's Observations

The Bench found this defense unconvincing. Justice Yadav, delivering the judgment, remarked that

“marks obtained are one of the most important aspects of a mark sheet, and it is almost impossible that one would forget them.”

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The Court held that the petitioner’s conduct did not indicate a bona fide mistake but a deliberate attempt to use a false document to secure employment.

The judges also underlined the importance of integrity in disciplined forces like the CRPF, observing that

"even a small breach of trust can endanger not only the organization’s credibility but also national security."

Addressing the plea of disproportionate punishment, the Court relied on Clause 10(2) of the Government of India’s DoPT Office Memorandum (1993), which mandates dismissal or removal of any government employee found to have submitted a false certificate at the time of appointment.

The bench noted that the CRPF authorities had conducted the inquiry as per due process, under Rule 14 of the CCS (CCA) Rules, 1965, and that the petitioner was given adequate opportunity to present his defense.

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Citing the Supreme Court’s observations in Ranjit Thakur v. Union of India (1987) and B.C. Chaturvedi v. Union of India (1995), the Court reiterated that judicial review does not extend to re-evaluating the quantum of punishment unless it “shocks the conscience” of the court. In this case, it said, the dismissal was both legally justified and proportionate.

Decision

Concluding its analysis, the Bench stated:

"The petitioner was fully aware of the document he was furnishing. He knew it was incorrect. The plea of bona fide mistake is an afterthought. Once trust is lost, the foundation of the employer-employee relationship collapses."

Rejecting the argument that his role as a "Water Carrier" was non-combative and hence less critical, the Court remarked that

"every post, however minor it may appear, carries weight in a security organization."

Holding that no procedural irregularity or violation of natural justice had occurred, the High Court dismissed the writ petition, affirming the CRPF’s decision to terminate Amit Kumar’s service.

The judgment ends with the clear message that honesty in recruitment documents is non-negotiable - especially in forces tasked with the nation’s security.

Case Title: Amit Kumar vs Union of India & Others

Case Number: W.P.(C) 8474/2019

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