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2026 Supreme(Cal) 204

IN THE HIGH COURT AT CALCUTTA
TAPABRATA CHAKRABORTY, PARTHA SARATHI CHATTERJEE, JJ.
Abhishek Maity - Appellant
Versus
The West Bengal State University & Ors. – Respondents
FMA 1219 of 2025 With IA No. CAN 1 of 2025
Decided On : 25-03-2026

Advocates Appeared:
For the Appellant : Mr. Kumarjyoti Tewari, Sr. Adv., Mr. Prantick Ghosh, Mr. Anirudh Tewari, Mr. Amrit Singh, Mr. Prasad Bhattacharya.
For the University : Mr. Santanu Kumar Mitra, Sr. Govt. Adv., Mr. Amartya Pal, Ms. Mahek Jaiswal.

Academic institutions are entitled to rely on their internal databases for verifying academic credentials. A court will not issue a writ compelling an institution to recognize documents that conflict with official records and are reasonably suspected of being forged, absent clear proof of their genuineness.

Headnote:(A) Right to Information Act, 2005 - Request for supply of examination records and post-review marksheets - Academic institution records failing to correlate with submitted marks - Discrepancy between candidate claims and official database - Petitioner seeking relief based on potentially fraudulent documents.

(B) Writ jurisdiction - Scope of judicial review - Courts cannot issue mandatory directions to institutions to validate documents inconsistent with primary records - Burden of proving genuineness of challenged documents rests with the individual - No interference warranted unless the decision below is found to be perverse or illegal. (Paras 31, 33, 37)

Facts of the case:
A student claimed to have improved marks in a degree examination after a re-evaluation process. Years later, while seeking an official pass certificate, the academic institution discovered that the marks presented by the student did not align with their secure database. The institution termed the documents as forged, citing systemic irregularities in past examinations. The petitioner sought a judicial order to treat the disputed marksheets as genuine.

Findings of Court:
The court found that the academic records maintained in the institution's database served as the primary source of truth. Since the document held by the petitioner contradicted these digital and physical records, the court concluded that the request was unjustified. Similar prior adjudications have consistently held that documents inconsistent with official records cannot be validated.

Issues: Whether the court can direct the issuance of academic certificates based on documents disputed by the institution and whether there exists sufficient evidence of perversity in the order of the lower bench.

Ratio Decidendi: The judiciary must defer to the reliability of an institutional database in matters of academic documentation. When an inconsistency is established between a candidate's submission and the institution's verified records, the burden of proving authenticity lies with the candidate. Judicial review does not extend to substituting records without verified evidence.

Result: Appeal dismissed.

Table of Content
1. narrative of disputed academic records and factual grievances. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11)
2. university's counter-verification and context of systemic document fraud. (Para 12 , 13 , 14 , 15 , 16)
3. parties' competing arguments regarding academic authenticity and record veracity. (Para 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25)
4. judicial assessment of evidence and authentication of marksheets. (Para 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34)
5. distinguishing precedents to uphold academic integrity requirements. (Para 35 , 36)
6. dismissal of appeal due to lack of merit. (Para 37)

JUDGMENT :

Partha Sarathi Chatterjee, J.

1. The present appeal challenges the legality and propriety of the order dated 19.06.2025 passed by the learned Single Bench in WPA 11863 of 2025, whereby the writ petition preferred by the writ petitioner/appellant (hereinafter referred to as ‘the appellant’) was dismissed.

2. Briefly stated, the facts, as projected by the appellant in his pleadings, are that the appellant, who was a student of Basirhat College in the District of North 24 Parganas, affiliated to West Bengal State University, completed his B.Sc. (Honours) in Chemistry in the year 2014. He initially received his marksheet dated 4th August, 2014 in respect of the Part-III examination, which reflected that he had been awarded 25 out of 100 and 29 out of 100 in CEMA Papers V and VI respectively.

3. Being dissatisfied with the marks so awarded, the appellant applied for review of the answer scripts of the said papers. Subsequently, a provisional marksheet dated 29.12.2014 was issued indicating that his marks in the said papers had been increased by 7 and 8 marks respectively, raising them to 32 and 37. Thereafter, the appellant received the final marksheet dated 19th April, 2015.

4. For the purpose of pursuing a B.Ed. course from another University, the appellant applied for a migration certificate. Upon verification of all his documents, including the marksheets, the University issued a migration certificate to the appellant on 7th October, 2015, granting him no objection to take admission to any course in another University.

5. In the year 2016, the appellant visited the University to collect his provisional certificate. At that time, the marksheet earlier issued to him was taken from his custody and he was informed that the marks in the said two papers, as reflected in his final marksheet, did not tally with the records maintained by the University. Thereafter, the appellant requested the University to return his original marksheet; however, the University did not accede to such request. Instead, by issuing a certificate, the University stated that the final marksheet submitted by the appellant was under verification and that the provisional certificate could not be issued to him until the verification process was completed.

6. In the meantime, the appellant qualified in the Teacher’s Eligibility Test (for short, ‘TET’) held on 16th August, 2015 and an interview list was published on 23rd August, 2019. However, owing to certain disputes, a writ proceeding was initiated in that regard. Ultimately, a panel was published on 23rd August, 2023, in which the appellant’s name appeared at serial no. 555. Pursuant thereto, the appellant joined Kumarpur Parashmoni Sikshbitan (H.S.) as a teacher on 6th December, 2024. However, approval of his appointment was granted subject to the condition that the appellant would furnish his final marksheet and original pass certificate.

7. On November 9, 2023, the appellant submitted an application under the relevant provisions of Right to Information Act, 2005 (for short, the 2005 Act) requesting information and supply of answer scripts of those two papers along with his post review mark sheet. However, despite receipt of such application, no documents had been supplied to the appellant which prompted the appellant to prefer an appeal under the 2005 Act.

8. Subsequently, by a letter dat

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