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Supreme Court Orders CBI Probe into Advocate’s Alleged Fake B.Com Degree from Magadh University

Top court directs central agency to verify authenticity of 1991 degree certificate

Bar Council’s documents claim mark sheet and degree were forged; report due by November 30

By Our Legal Correspondent

New Delhi, September 18, 2025 :

The Supreme Court of India has ordered the Central Bureau of Investigation (CBI) to conduct a detailed probe into allegations that an advocate’s Bachelor of Commerce (Honours) degree from Magadh University, Bodh Gaya is fake.

The case involves Advocate Naresh Dilawari, who is accused of submitting a forged B.Com degree and mark sheet from the 1991 examination. The court’s decision came after the Bar Council of Punjab and Haryana produced documents from the university stating that the degree was never issued.

How the Case Reached the Supreme Court

The matter was heard by a bench of Justice Manoj Misra and Justice Ujjal Bhuyan in the case Naresh Dilawari v. Charanjit Singh Oberoi.

The Bar Council had filed Interlocutory Application No. 161167/2025, seeking to place additional documents on record. Among them was Annexure A-3 — a letter from the Controller of Examinations, Magadh University — which stated that the petitioner’s B.Com (Accounts) Honours mark sheet and degree certificate, allegedly issued in August 1991, were forged and not issued by the university.

Earlier Court Directions

On August 1, 2025, the Supreme Court had directed the petitioner to submit photocopies of the degrees under which he claimed to be a graduate in Commerce and Law.

In compliance, Dilawari submitted a photocopy of the B. Com (Honours) degree. However, the respondent’s counsel pointed to the university’s letter declaring the documents fake.

Petitioner’s Defence

Dilawari argued that the university’s records were torn or damaged, making it difficult to verify the degree’s authenticity. He referred to Annexure A-2 of the Bar Council’s application, which mentioned the poor condition of the records.

Supreme Court’s Observations

The bench noted that there was a clear dispute over the veracity of the degree and that the matter required an independent investigation.

Quoting from the order:

“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.”

CBI Investigation Ordered

The court directed the Director of the CBI to appoint an officer to investigate the authenticity of the degree and submit a report by November 30, 2025.

The matter has been listed for further hearing on December 9, 2025.

Why This Case Matters

The case highlights the seriousness of forged educational qualifications in the legal profession. Advocates are officers of the court, and their credibility is essential for the justice system.

If the allegations are proven, it could lead to disciplinary action by the Bar Council, including suspension or disbarment, and possible criminal charges for forgery and fraud.

Magadh University’s Role

Magadh University, located in Bodh Gaya, Bihar, is one of the largest universities in the state. The Controller of Examinations’ letter was central to the case, as it categorically denied issuing the degree in question.

The university’s statement was based on its official records, which, despite some being damaged, were sufficient to conclude that the petitioner’s documents were not genuine

Bar Council’s Stand

The Bar Council of Punjab and Haryana has been pursuing the matter to ensure that only qualified individuals are allowed to practice law. The Council’s disciplinary committee had earlier examined the issue, leading to the current proceedings in the Supreme Court.

Legal Context

Under Indian law, producing a forged degree can attract charges under:

Section 420, IPC — Cheating and dishonestly inducing delivery of property
Section 468, IPC — Forgery for the purpose of cheating
Section 471, IPC — Using as genuine a forged document

In addition, the Advocates Act, 1961 empowers Bar Councils to take disciplinary action against advocates found guilty of professional misconduct, which includes misrepresentation of qualifications.

Next Steps

The CBI will now:

Verify University Records — Cross-check the petitioner’s degree and mark sheet against Magadh University’s archives.
Interview Officials — Speak to current and former university staff.
Examine Related Documents — Look into admission records, examination registers, and issuance logs from 1991.
Submit Report — Present findings to the Supreme Court by November 30, 2025.

Possible Outcomes

If Genuine: The petitioner’s name will be cleared, and the Bar Council’s case may collapse.
If Forged: The petitioner could face criminal prosecution and professional disqualification.

Case Snapshot

Case Title	*Naresh Dilawari v. Charanjit Singh Oberoi*
Order Date	September 15, 2025
Bench	Justice Manoj Misra, Justice Ujjal Bhuyan
Key Allegation	Forged B.Com (Honours) degree from Magadh University, 1991
Investigation Agency	CBI, Delhi
Report Due	November 30, 2025
Next Hearing	December 9, 2025

Conclusion

The Supreme Court’s order sends a strong message that integrity in the legal profession is non-negotiable. By involving the CBI, the court has ensured that the investigation will be thorough and independent.

The outcome of this case could set an important precedent for how allegations of forged educational qualifications are handled — not just for lawyers, but for all professions where public trust is paramount.