CBI finds Naresh Dilawari's B.Com degree fake; Supreme Court gives 30 days to challenge removal

The Supreme Court of India has disposed of an appeal by advocate Naresh Dilawari, whose B.Com degree from Magadh University was found prima facie fake and forged by the Central Bureau of Investigation. The Court gave him 30 days to challenge his removal from the roll of the Bar Council of Punjab and Haryana.

A Degree Under Scrutiny

The controversy began when a complaint was lodged against Naresh Dilawari, an advocate practising since 2001 with a licence from the Bar Council of Punjab and Haryana. By an order dated 20 December 2021, the Bar Council suspended his right to practise for two years. Dilawari appealed to the Disciplinary Committee of the Bar Council of India (BCI), which on 16 January 2025 directed the Bar Council to verify the genuineness of his educational qualifications and keep his licence suspended pending inquiry.

Doubts about Dilawari's B.Com degree—allegedly obtained in 1991 from Magadh University, Bodh Gaya—prompted the Supreme Court to act. On 15 September 2025, the Court directed the Central Bureau of Investigation (CBI) to investigate whether the degree was genuine or forged. The CBI submitted a status report in a sealed cover, which was opened in Court.

CBI's Prima Facie Finding

The CBI report concluded that " prima facie , commission of cognizable offences of forgery, fabrication of public documents etc., have been made out against the appellant-in-person and other unknown persons." This finding was recorded in the Supreme Court's order of 17 August 2026 . The Court also took note of a communication from the Controller of Examinations of Magadh University stating that the mark sheet and B.Com degree standing in Dilawari's name were "forged and not issued from the University."

The Bar Council's Action

Meanwhile, pursuant to the BCI Disciplinary Committee's direction, the Bar Council of Punjab and Haryana conducted an inquiry and submitted an Inquiry Report on 11 June 2025. On 6 July 2025, the BCI Disciplinary Committee directed the removal of Dilawari's name from the roll of the Bar Council and ordered him to surrender his licence. This was formalised in a notification dated 5 August 2025.

Appellant's Challenge

Appearing in person before the Supreme Court, Dilawari argued that the BCI Disciplinary Committee had "exceeded its jurisdiction" in ordering a fresh inquiry and subsequently directing his removal from the roll. He contended that such actions were clearly beyond the Committee's powers.

Supreme Court's Direction

The Supreme Court, however, did not examine the merits of this challenge. The bench—comprising Justice Ujjal Bhuyan and Justice Atul S. Chandurkar—observed: " Without expressing any opinion on merit , we are of the view that appellant-in-person may assail the legality and validity of the notification dated 05.08.2025 in an appropriate proceeding before the appropriate forum ." The Court added that if such proceedings are filed within 30 days from 17 August 2026 , the question of limitation shall not bar consideration of the challenge. All contentions of the appellant were kept open.

Key Observations

The Court recorded the CBI's finding verbatim, noting that it established " prima facie , commission of cognizable offences of forgery, fabrication of public documents etc." against Dilawari and unknown persons. The order also noted the University's assertion that the degree documents were forged.

Court's Decision

The Supreme Court disposed of the civil appeal and all pending applications, granting Dilawari the liberty to challenge the removal notification before the appropriate forum within 30 days. The implications are significant: the Court has left the substantive dispute—whether the degree is genuine and whether the BCI's action was within its jurisdiction—to be adjudicated in fresh proceedings. This allows Dilawari a final opportunity to contest the findings that could end his legal career, while the CBI's involvement underscores the seriousness of the allegations.