Case Law
Subject : Professional Misconduct - Document Forgery
Description :
New Delhi: In a significant development, the Supreme Court of India has directed the Central Bureau of Investigation (CBI) to investigate the authenticity of a Bachelor of Commerce (B.Com) degree belonging to appellant Naresh Dilawari. The order was passed by a bench comprising Justice Manoj Misra and Justice Ujjal Bhuyan after serious allegations of forgery were raised during the hearing of a civil appeal.
The case, Naresh Dilawari vs Charanjit Singh Oberoi , took a critical turn when the court's attention was drawn to the potential forgery of the appellant's B.Com degree, which he claimed to have obtained from Magadh University in 1991. The issue of the degree's veracity became a central point of contention, prompting the court to delve deeper into the matter.
Earlier, on August 1, 2025, the court had taken on record documents filed by the Bar Council of Punjab and Haryana. Among these was a crucial letter from the Controller of Examinations, Magadh University, Bodh Gaya. This letter explicitly stated that upon verification, the mark sheet and degree certificate of Naresh Dilawari (Roll-PAT-16335, Regd No. 2870/88) were found to be "forged and not issued from the University."
The counsel for the respondent, Charanjit Singh Oberoi, vehemently argued that the university's official communication confirmed the degree was fake and urged the court to take cognizance of this serious allegation.
In his defense, the appellant, Naresh Dilawari, who appeared in person, pointed to another document suggesting that the university's records were torn. He contended that the inability to verify his degree could be due to the poor condition of the university's records rather than any act of forgery on his part.
Finding the conflicting claims and the gravity of the allegation warranted a thorough investigation, the Supreme Court bench decided to entrust the matter to a premier investigating agency. In its order dated September 15, 2025, the court observed:
"Be that as it may, as an issue regarding veracity of a degree has arisen, we deem it appropriate to require the Central Bureau of Investigation, Delhi to do the investigation and ascertain whether the degree set up by the Petitioner of having passed the B.Com examination from Magadh University in the year 1991 is genuine or forged."
The court has directed that a copy of its order be sent to the Director of the CBI, who will depute an officer to conduct the investigation. The CBI is mandated to submit its report on the genuineness of the degree by November 30, 2025.
The case is scheduled to be listed for the next hearing on December 9, 2025, when the court will consider the CBI's findings. The outcome of this investigation could have significant implications for the appellant and raises broader questions about the verification processes for educational qualifications required for professional practice.
#SupremeCourt #CBIProbe #LegalEthics
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