THE STATE OF JHARKHAND & ORS. versus RANJAN KUMAR & ORS.

Citation: [2026] 5 S.C.R. 522 · Decided: 08-05-2026 · Supreme Court of India · Bench: AHSANUDDIN AMANULLAH · Disposal: Appeal(s) allowed

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Judgment (excerpt)

[2026] 5 S.C.R. 522 : 2026 INSC 466
The State of Jharkhand & Ors. 
v. 
Ranjan Kumar & Ors.
(Civil Appeal No. 7364 of 2026)
08 May 2026
[Ahsanuddin Amanullah and R. Mahadevan,* JJ.]
Issue for Consideration
Issue arose for consideration whether the disciplinary action taken 
against respondent No.1, culminating in his removal from service, 
suffers from any legal infirmity warranting interference.
Headnotes†
Service law – Dismissal from service – Respondent No.1 
secured appointment as a Constable under the name “SK” 
with Bihar Police while continuing in service as a Constable in 
the Jharkhand Police under the name “RK” through fabricated 
documents and thereafter remained unauthorisedly absent 
from service – Memorandum of charge issued in view of the 
serious irregularities committed to which respondent no.1 
submitted written statement of defence – Inquiry Officer 
thereafter submitted his report – Thereafter, the Superintendent 
of Police dismissed respondent No.1 from service – Concurrent 
findings of fact recorded by the disciplinary authority, the 
appellate authority and the revisional authority that the charges 
of fraud, impersonation, forgery, cheating, unauthorised 
absence from duty and violation of service discipline stood 
proved – Single Judge of the High Court upheld the dismissal, 
however, the Division Bench of the High Court set aside the 
same – Correctness:
Held: Member of the police force expected to maintain the 
highest degree of integrity, honesty and discipline – Fraud at the 
threshold of entry into service strikes at the very root of public 
employment – On facts, material available goes far beyond mere 
suspicion and reasonably establishes a conscious course of deceit 
adopted by respondent No.1 for obtaining employment benefits 
* Author
[2026] 5 S.C.R. 
523
The State of Jharkhand & Ors. v. Ranjan Kumar & Ors.
from two sovereign employers in a disciplined force – Single 
Judge correctly appreciated the limited scope of judicial review 
and declined to substitute judicial opinion in place of the findings 
recorded in the disciplinary proceedings – However, the Division 
Bench, clearly transgressed the settled parameters of judicial 
review by reappreciating the evidence and disturbing concurrent 
findings of fact recorded by the disciplinary authority, Appellate 
Authority and Revisional Authority – Such approach cannot 
be countenanced in law – Respondent No.1 was duly served 
with a charge memorandum, furnished with relevant materials, 
afforded adequate opportunity to submit his defence, participated 
in the enquiry proceedings, received copy of the enquiry report, 
and submitted his representation thereon – Requirements of 
procedural fairness and substantial compliance with the prescribed 
procedure thus stand satisfied – Since the allegations levelled 
against respondent no.1 pertain to impersonation, fraud, use of 
forged credentials, dual employment in police departments and 
unauthorised absence, the continuance of such an employee 
in service would be wholly detrimental to institutional discipline, 
public confidence, and the credibility of the police force – Order 
of dismissal passed against respondent no.1 was a proportionate 
and justified administrative measure arising out of a fair and lawful 
enquiry – Thus, the Division Bench not justified in reappreciating the 
evidence and setting aside the punishment imposed – Allegations, 
reinforced by forensic findings, prima facie disclose the commission 
of cognizable offences such as cheating, impersonation, forgery, 
use of forged documents and furnishing false information to 
public authorities  – Public employment, particularly in the police 
service, cannot be converted into an instrument of fraud – If 
individuals entrusted with enforcing the law themselves secure 
entry into service through deception and fabricated credentials, 
it would seriously erode the rule of law – In these circumstances, 
while restoring the disciplinary action, it is both necessary and 
appropriate to direct initiation of criminal proceedings in accordance 
with law – Matter to be examined by the competent jurisdictional 
police authority and appropriate steps be taken, in accordance 
with law – Impugned judgment of the Division Bench set aside, 
and that of the Single Judge along with the order of dismissal 
passed by the disciplinary authority, as affirmed by appellate 
authority and revisional authority stands restored – Patna District 
524
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