The Supreme Court on September 8, 2026, upheld the dismissal of a challenge to the appointment of an Assistant Professor in Physical Education at Sat Jinda Kalyana College, Rohtak, while directing Maharshi Dayanand University to conduct a fresh inquiry into the authenticity of the appointee’s Ph.D. degree.
A Bench of Justice Dipankar Datta and Justice Manmohan dealt with allegations concerning a Ph.D. degree said to have been awarded by Bundelkhand University, Jhansi. The Court found that the degree was not an essential qualification for the post because the candidate had independently qualified the UGC-NET examination.
Background of the Case
The dispute arose after Sat Jinda Kalyana College advertised an Assistant Professor post in Physical Education in February 2018. Annu Kumar and another candidate, along with several others, applied. The sixth respondent was selected, while the appellants did not appear in the merit list.
A query made under the Right to Information Act later produced information from Bundelkhand University stating that the sixth respondent had not attended any Ph.D. programme there during the relevant period. Documents placed before the Supreme Court also raised serious questions about the authenticity of the degree and related documents.
The Punjab and Haryana High Court had dismissed the challenge, holding, among other things, that the sixth respondent possessed UGC-NET qualification and therefore met the applicable eligibility requirement.
Supreme Court’s Observation
The Supreme Court examined the regulations applicable when the advertisement was issued. It held that the Ph.D. was not a mandatory qualification for this appointment. Candidates without NET/SLET/SET qualification could rely on a qualifying Ph.D., while the sixth respondent had already cleared UGC-NET.
The Bench also explained the standard required for a writ of quo warranto, a legal remedy used to question whether a person is lawfully holding a public office.
"The burden of proof has to be discharged by the writ petitioner by producing unimpeachable evidence in support of his assertion."
The Court, however, noted that the disputed Ph.D. might have helped the sixth respondent gain additional marks in the selection process.
Decision
The Supreme Court declined to disturb the appointment but directed Maharshi Dayanand University to conduct an inquiry into the Ph.D. degree. The sixth respondent must produce the original degree before university officials, while officials from Bundelkhand University must produce the documents supporting their disclosures. The sixth respondent will also have an opportunity to defend himself and cross-examine witnesses.
The Court clarified that if the inquiry finds the Ph.D. to be forged, the concerned institutions or others may provide information to the police for prosecution in accordance with law.
The civil appeals were disposed of on these terms, with parties directed to bear their own costs.
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