The Patna High Court has set aside the dismissal of a Punjab National Bank (PNB) officer accused of impersonation during a recruitment examination, holding that the bank relied on a handwriting expert’s report without examining its author or any supporting witness during the departmental inquiry. Justice Kumar Manish directed the bank to reinstate the officer, Rahul Kumar Gautam, with continuity of service, back wages and consequential benefits.
Background
Gautam was selected as a probationary officer following the Institute of Banking Personnel Selection (IBPS) recruitment process and joined PNB on February 16, 2015. A complaint subsequently alleged that someone else had appeared in his written examination on October 20, 2013.
The bank initiated disciplinary proceedings based on a forensic handwriting report that identified differences between the questioned and standard signatures. However, the fingerprint bureau found the relevant thumb impressions unsuitable for comparison because they were blurred and lacked sufficient ridge details.
The inquiry officer held the charge proved, and the bank dismissed Gautam on March 31, 2018. His statutory appeal was rejected as time-barred on May 7, 2024.
The High Court found that the bank had not examined the handwriting expert who prepared the report, any examination invigilator, or another competent witness to establish the authenticity and contents of the documents relied upon.
Relying on the Supreme Court’s decision in Roop Singh Negi v. Punjab National Bank, the Court reiterated:
“Suspicion, as is well known, however high may be, can under no circumstances be held to be a substitute for legal proof.”
The Court also referred to State of Uttar Pradesh v. Ram Prakash Singh, emphasising that documents relied upon in disciplinary proceedings must be properly proved through competent evidence.
It further noted that the alleged examination irregularity predated Gautam’s appointment and questioned the application of the bank’s service regulations in the absence of properly established evidence.
The Court observed:
“A document does not prove itself. In the enquiry, therefore, the contents of the relied-on documents have to be proved by examining a witness having knowledge of the contents of such documents and who can depose as regards its authenticity.”
The High Court allowed the writ petition and quashed both the dismissal order dated March 31, 2018, and the appellate order dated May 7, 2024. It declined to send the matter back for a fresh inquiry, noting that the bank had already received a full opportunity to establish its case.
The Court directed the bank to reinstate Gautam in his former or an equivalent post, with continuity of service and consequential benefits.
It also ordered payment of back wages and other applicable service benefits from the date of dismissal until actual reinstatement, within three months of receiving or being presented with a copy of the judgment.
Case Details
- Case Title: Rahul Kumar Gautam v. Punjab National Bank & Others
- Case Number: Civil Writ Jurisdiction Case No. 8728 of 2018
- Judge: Justice Kumar Manish
- Decision Date: October 15, 2026
