Police Constable Who Secures Dual Appointment by Impersonation and Forged Identity Cannot Be Protected by Reappreciating Evidence in Writ Jurisdiction

Case Name: The State of Jharkhand & Ors. v. Ranjan Kumar & Ors.

Citation: 2026 INSC 466

Date of Judgment/Order: 8 May 2026

Bench: Justice Ahsanuddin Amanullah and Justice R. Mahadevan

Held: The Supreme Court held that in departmental proceedings, particularly involving a disciplined police force, the High Court cannot act as an appellate authority and reappreciate evidence when the disciplinary authority, appellate authority and revisional authority have recorded concurrent findings based on relevant material. The Court held that strict rules of evidence do not apply to departmental enquiries and the applicable standard is preponderance of probabilities. Where a police constable is found to have secured or attempted to secure dual appointments in two State police forces by using different names, altered parentage particulars, forged documents and impersonation, dismissal from service is a proportionate and justified penalty.

Summary: Respondent No. 1, Ranjan Kumar, was appointed as a Constable in the Jharkhand Police on 18 May 2005. After being granted compensatory leave in December 2007, he failed to rejoin duty and was alleged to have secured appointment as Constable in Bihar Police under the name “Santosh Kumar”, son of Kamta Sharma, while his Jharkhand service records described him as “Ranjan Kumar”, son of Kamta Singh. Departmental proceedings were initiated on the basis of appointment forms, photographs, certificates, official communications and reports from the Bihar authorities. The disciplinary authority dismissed him from service, and the appellate and revisional authorities affirmed the punishment. The learned Single Judge of the Jharkhand High Court dismissed his writ petition, but the Division Bench interfered, holding that the charge was not proved. The Supreme Court held that the Division Bench exceeded the settled limits of judicial review by reappreciating evidence in a disciplinary matter. The Court also relied on the later enquiry ordered by it, in which Bihar Police submitted a report showing through forensic comparison of fingerprints, biometric records and photographs that “Ranjan Kumar” and “Santosh Kumar” were one and the same person.

Decision: The Supreme Court allowed the appeal, set aside the judgment of the Division Bench of the Jharkhand High Court dated 25 August 2022, and restored the judgment of the learned Single Judge along with the dismissal order dated 20 August 2010 passed by the disciplinary authority, as affirmed by the appellate and revisional authorities. The Court further directed the Director General of Police, Bihar and the Director General of Police, Jharkhand to ensure that the matter is examined by the competent jurisdictional police authority for initiation of appropriate criminal proceedings in accordance with law. Exercising powers under Article 142 of the Constitution, the Court also quashed Patna District Order No. 10524 of 2007 dated 26 December 2007 and set aside the appointment of Respondent No. 3, “Santosh Kumar”, son of Kamta Sharma, as Constable in Bihar Police, with legal consequences to follow. Pending applications were disposed of with no order as to costs.