News Citation : 2026 LN (HC) 212 | 2026:CGHC:13854
March 23, 2026 : The Chhattisgarh High Court has upheld the dismissal of a government school teacher who was found to have secured his job using a forged B.Ed marksheet, ruling that the termination was legally valid even without a full departmental inquiry.
The case involved Seetaram Sahu, a teacher who had been working since 2007 after being appointed as Shikshakarmi Grade-II and later confirmed in service. His employment was terminated in June 2024 after authorities discovered that the B.Ed marksheet he had submitted at the time of appointment was not genuine.
Sahu challenged the termination before the High Court, arguing that as a confirmed employee, he could not be dismissed without a formal departmental inquiry. He claimed the action violated principles of natural justice, particularly the requirement of a fair hearing and due process.
The state, however, maintained that the dismissal was justified. Officials pointed out that the marksheet had been verified by Pt. Ravishankar Shukla University, Raipur, which confirmed that the document was not issued by the university and did not match its official records. The petitioner was also given notice and an opportunity to respond before the termination order was passed.
Justice Parth Prateem Sahu, delivering the judgment, noted that the petitioner did not contest the core allegation that the marksheet was forged. Instead, his challenge was limited to procedural grounds. The court observed that Sahu had been given notice, had appeared before authorities, and had admitted he had no other valid B.Ed marksheet.
Relying on several Supreme Court rulings, the court emphasized that fraud vitiates all proceedings. It held that when employment is obtained through fraudulent means, the very foundation of the appointment collapses. In such cases, strict adherence to procedural safeguards like a full departmental inquiry is not always necessary, especially when no real prejudice is caused to the employee.
The court also clarified that the principles of natural justice are flexible and must be applied based on the facts of each case. Where the facts are undisputed and only one conclusion is possible, setting aside an order on technical grounds would serve no purpose.
Importantly, the judgment reiterated that a person who secures employment through fraud cannot claim constitutional protections available to validly appointed public servants. The court concluded that Sahu’s appointment was void from the outset due to the use of a forged document.
Finding no legal flaw in the termination process, the High Court dismissed the writ petition and upheld the state’s decision to remove the teacher from service.
Case Reference : WPS No. 6609 of 2025, Seetaram Sahu v. State of Chhattisgarh & Others; Counsel for Petitioner: Mr. Pawan Shrivastava, Advocate; Counsel for Respondents/State: Mr. Ajay Kumrani, Panel Lawyer.
