The Supreme Court has set aside the dismissal of a court attender in Telangana, holding that a serious charge such as forgery cannot be sustained in disciplinary proceedings without credible evidence, particularly where handwriting comparison or expert examination was not undertaken.
The Bench of Justice K.V. Viswanathan allowed the appeal filed by K. Rajaiah, who had been dismissed from service after a departmental inquiry concluded that he submitted a fabricated medical certificate to justify his absence from duty.
K. Rajaiah, appointed as an attender in 1998 in the Court of the Additional Senior Civil Judge, Karimnagar, was absent from duty between August 3 and August 7, 2017. He later submitted an explanation stating that he had been ill and had consulted a local medical practitioner, producing a handwritten medical certificate in support of his claim.
Initially, his salary for the period of absence was deducted, and the matter appeared to have been closed after he submitted an explanation. However, the issue resurfaced when the doctor whose certificate was produced stated that he had not issued the document, leading to disciplinary proceedings.
Two charges were framed against Rajaiah: unauthorized absence and submission of a fabricated medical certificate amounting to misconduct.
Following an inquiry, both charges were held proved, and Rajaiah was dismissed from service in November 2018. His appeal before the High Court failed, prompting him to approach the Supreme Court.
The central question before the Court was whether the disciplinary findings—particularly the conclusion that the medical certificate was forged—were supported by reliable evidence and whether the dismissal could be sustained in judicial review.
The Court closely examined the evidence and noted several important factors. The doctor admitted that Rajaiah had consulted him and received medication. The doctor acknowledged that the letterhead used in the certificate belonged to him and did not dispute the rubber stamp. The certificate in question was handwritten, and the authenticity of the signature was disputed.
The Court held that the inquiry officer should have compared disputed and admitted signatures or referred the matter to a handwriting expert before concluding that the certificate was fabricated.
The Bench emphasized that where the charge is grave—such as forgery—the standard of scrutiny must be correspondingly higher, and conclusions cannot be based merely on one person’s assertion against another’s.
After examining the original disciplinary records, the Supreme Court observed that even the undisputed signatures of the doctor were not identical, and the similarities and differences in signatures required expert evaluation.
The Court concluded that the finding of forgery was perverse and unsupported by credible evidence, making the disciplinary action unsustainable.
The Court also pointed out procedural and factual peculiarities. Rajaiah had already been penalized through deduction of salary for the absence.
K. Rajaiah Evidence suggested that proceedings had initially been dropped after his explanation. The issue was reopened later without clear justification, and the doctor’s preliminary statement was recorded in the employee’s absence.
These factors further weakened the case against the employee.
Reiterating established law, the Supreme Court observed that while courts exercising judicial review do not normally re-appreciate evidence in disciplinary matters, they can intervene where findings are unsupported by evidence, perverse, or reached in violation of principles of fairness and natural justice.
Case Details
Case Title: K. Rajaiah Versus The High Court for the State Of Telangana
Case No.: Special Leave Petition (C) No.11965 of 2024
Date: 11/02/2026
