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The State of Jharkhand & Ors. v. Ranjan Kumar & Ors.

Civil Appeal · 2026 INSC 466Decided 8 May 2026
C.A. No.-007364-007364 - 2026 (arising out of SLP (C) No. 6111 of 2023)
Justice Ahsanuddin Amanullah · Justice R. Mahadevan

Background

Ranjan Kumar, a Jharkhand Police Constable, went unauthorisedly absent after availing compensatory leave in December 2007, and during that absence allegedly secured a second appointment as a Constable in the Bihar Police under a fabricated identity ("Santosh Kumar") using forged certificates. A departmental enquiry in Jharkhand found the two identities were the same person, and he was dismissed from service; his statutory appeal and revision were also rejected. His writ petition was dismissed by a Single Judge of the Jharkhand High Court, but a Division Bench, in a Letters Patent Appeal, reversed this and quashed his dismissal, holding there was insufficient evidence. The State of Jharkhand appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that the Division Bench had exceeded the limited scope of judicial review under Article 226 by re-appreciating evidence and overturning concurrent factual findings reached by the disciplinary, appellate and revisional authorities, which is impermissible absent manifest illegality. It found that Ranjan Kumar had in fact been given a proper charge memorandum, the enquiry report, and a fair opportunity to defend himself, so procedural fairness was satisfied. Given that impersonation, forgery, and holding dual police employment under a false identity were established, the Court restored his dismissal, and additionally used its powers under Article 142 to quash the fraudulent Bihar Police appointment itself and directed the police authorities of both Bihar and Jharkhand to examine the matter for initiation of criminal proceedings (cheating, forgery, impersonation) against him.

Lesson Learnt

Courts reviewing disciplinary dismissals cannot simply re-weigh the evidence and substitute their own view for well-supported factual findings of the disciplinary authority; separately, obtaining public employment (especially in the police) through impersonation and forged documents can lead to both dismissal from service and independent criminal prosecution.

Official source (sci.gov.in)View Judgment (PDF)

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