MP High Court Orders LIC to Reinstate Employee Dismissed for Digital Caste Certificate Issue

Madhya Pradesh High Court has quashed LIC’s Dismissal of Employee Over Non-Submission of Digital Caste Certificate. The petitioner, Manoj Verma, had been employed as a Development Officer at the Life Insurance Corporation (LIC) since September 12, 1992. At the time of his appointment, Verma submitted a caste certificate that was duly verified. Over the next 33 years of service, he consistently performed well and was recognized as one of the top employees in his division. In 2002, a complaint was raised alleging that his caste certificate was fraudulent, but the complaint was later retracted, and the certificate was confirmed as valid.

However, in 2022, LIC issued a charge sheet against Verma, citing that the Revenue Authority was unable to locate records related to his caste certificate. Subsequently, during ongoing departmental proceedings, LIC dismissed Verma for failing to submit a fresh digital caste certificate, as per a circular issued on January 3, 2014. Verma contended that the insistence on a new digital certificate was unreasonable, particularly since the original certificate had been verified decades ago and no evidence of fraud had emerged.

Arguments

Senior Counsel A.K. Sethi’s Argument for the Petitioner

Senior Counsel A.K. Sethi, representing Verma, argued that the original caste certificate, issued in 1990, was valid and had been verified by the authorities at the time of his appointment. He highlighted that the inability of the Revenue Authority to locate the records should not be construed as evidence that the certificate was false. Sethi also pointed out that Verma had applied for a new caste certificate, but due to procedural backlogs, there had been delays in issuing the updated document. He argued that dismissing Verma after 33 years of unblemished service for this procedural delay was arbitrary and violated principles of natural justice.

LIC’s Counsel Ms. Jyoti Tiwari’s Argument

Counsel for LIC, Ms. Jyoti Tiwari, argued that the dismissal was lawful under Clause 3 of the 2014 circular, which required employees to submit updated digital caste certificates. She asserted that since Verma had not complied, LIC was compelled to terminate his employment. Tiwari also mentioned that other employees had adhered to the requirement, making Verma’s failure to do so inexcusable.

Court’s Reasoning

The Court examined Clause 3 of the 2014 circular, which mandates disciplinary action if an employee fails to submit a valid caste certificate. The Court noted that the purpose of the circular was to address cases where the authenticity of a caste certificate was in question. However, in Verma’s case, no evidence of fraud or forgery was presented. The report from the Revenue Authority confirmed that the records were simply unavailable, and not that the certificate was fraudulent.

The Court emphasized that the absence of records does not automatically imply that the certificate is false or that there was any misrepresentation. Since the 1990 certificate had been issued by a competent authority, and no prescribed format was required at the time, the Court found no basis for treating it as invalid. The Court further held that Verma’s dismissal based solely on the failure to submit a digital certificate—when he had already applied for one—was unreasonable.

The Court also criticized LIC for failing to present any evidence of wrongdoing and for not taking action against the issuing officer for the missing records. Lastly, the Court noted that Verma’s application for a new caste certificate was still pending and emphasized that dismissing an employee due to procedural delays in government offices, especially after decades of unblemished service, was arbitrary and disproportionate.

Conclusion

The Court quashed LIC’s dismissal order and directed the reinstatement of Manoj Verma, acknowledging that the action taken by the corporation was unjustified and violated principles of natural justice.