Disposed¶63

Parimala, D/O.T.Nedumaran, v. the Registrar

Madras HC1 Jul 2026WP(MD)/7932/2017

Case brief

AI extract

What is this about?

Madras High Court (Madurai Bench), W.P(MD) 7932 of 2017, decided 01.07.2026 by Justice M. Dhandapani: genuineness of university mark statements and certificates — disputed questions of fact not adjudicable under Article 226; determination left to competent criminal court/forum; writ petition disposed with liberty to pursue remedies post criminal proceedings. Keywords: Anna University; forged bonafide certificates; MRM Xerox Centre; CSR No.67/2012; FIR No.46/2012; certificate dated 15.03.2011; CS9152 Database Technology; W.P.(MD) No.13582 of 2013; W.A.(MD) No.962 of 2014; Cont.P.(MD) No.529 of 2014.

What did the court decide?

No substantive relief; writ petition disposed of with no costs, and liberty granted to the petitioner to work out her remedies before the appropriate forum after the conclusion of the criminal proceedings. ¶63

Parimala, D/O.T.Nedumaran, Vs the Registrar — Writ and Judicial Review | Madras HC (2026)

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the certificates relied upon by the petitioner are genuine or forged — an issue involving disputed questions of fact not amenable to adjudication under Article 226.

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Court's answer

The issue of genuineness of the certificates involves serious disputed questions of fact requiring appreciation of evidence, which cannot be undertaken in exercise of the extraordinary jurisdiction under Article 226 of the Constitution of India.

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Ratio / Principle

The genuineness of the documents relied upon by the petitioner can be determined only by the competent criminal court or any other forum before which the issue is pending.

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Key takeaways

In view of the above, this Court is not inclined to adjudicate the disputed questions of fact involved in the present writ petition.ratio¶62
Liberty is granted to the petitioner to work out her remedies before the appropriate forum after the conclusion of the criminal proceedings or upon the competent authority rendering its findings regarding the genuineness of the documents.ratio¶62

Detailed headnote1 paragraphs

Madurai Bench of Madras High Court — W.P(MD)No.7932 of 2017 (connected W.M.P.(MD).No.6149 of 2017), decided 01.07.2026 by M. Dhandapani, J. Parimala, who completed the M.E. (Computer Science) Part-Time course (academic years 2009–2012) under the erstwhile Anna University of Technology, Tiruchirappalli, challenged the original II Semester mark statement issued by the Registrar, Anna University, and sought genuine copies of her semester mark statements, provisional certificate and degree certificate. She relied on a certificate dated 15.03.2011 certifying a pass in all II Semester subjects (examination held December 2010). After earlier rounds — W.P.(MD) No.13582 of 2013 (order dated 28.01.2014 directing issuance within one week), W.A.(MD) No.962 of 2014 (dismissed as withdrawn) and Cont.P.(MD) No.529 of 2014 (during which the respondent furnished the documents) — the petitioner alleged the supplied II Semester mark statement showed her failed in CS9152 – Database Technology contrary to the earlier certificate. The University countered that the certificate was unauthorised, without jurisdiction, and possibly forged, citing its complaint dated 29.06.2012 against M/s. MRM Xerox Centre (CSR No.67/2012; FIR No.46/2012 dated 08.08.2012, later withdrawn). Holding that genuineness of the certificates involved serious disputed questions of fact requiring appreciation of evidence, unfit for adjudication under Article 226 and determinable only by the competent criminal court or other forum, the Court disposed of the writ petition, granting the petitioner liberty to work out her remedies after conclusion of the criminal proceedings. No costs; connected miscellaneous petition closed.

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W.P(MD)No.7932 of 2017

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BEFORE THE MADURAI BENCH OF MADRAS HIGH COURT

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DATED: 01.07.2026

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CORAM

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THE HONOURABLE MR.JUSTICE M.DHANDAPANI

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W.P(MD)No.7932 of 2017 and W.M.P.(MD).No.6149 of 2017

Parimala

... Petitioner

The Registrar, Anna University, Guindy, Chennai. ... Respondent

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PRAYER: Writ Petition filed under Article 226 of Constitution of India, to issue a Writ of Certiorari fied Mandamus, calling for the records relating to the original mark statement for second semester issued by the respondent to the petitioner and quash the same and consequently direct the respondent to issue the true copies of original mark statements for the second semester issued by the Anna University, Tricy and sixth semester issued by the Anna University, Chennai, provisional Certificate and degree certificate of M.E., Computer Science part time course for the academic year 2009-2012 to the petitioner by considering the petitioner's representation dated 15.04.2013.

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https://www.mhc.tn.gov.in/judis

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For Petitioner : Mr. S.Siva Thilakar For Respondent : No Appearance

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W.P(MD)No.7932 of 2017

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ORDER

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This Writ Petition has been filed challenging the original II Semester mark statement issued by the respondent to the petitioner and seeking to quash the same. The petitioner has further sought a consequential direction to the respondent to issue the genuine II Semester mark statement issued by Anna University, Tiruchirappalli, the VI Semester mark statement issued by Anna University, Chennai, the Provisional Certificate, and the Degree Certificate for the M.E. (Computer Science) Part-Time course for the academic years 2009–2012, by considering the petitioner's representation dated 15.04.2013.

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2. The learned counsel appearing for the petitioner submitted that the petitioner completed her B.E. (Electronics and Communication Engineering) at Seethaiammal Engineering College, Keelakandani, Sivagangai District, in the year 2009. Thereafter, she was employed as a Lecturer in a private Engineering College and consequently joined the M.E. (Computer Science) Part-Time course

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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under Anna University of Technology, Tiruchirappalli, during the academic year 2009–2010. According to the petitioner, she successfully completed all the semesters.

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3. It is further submitted that, since the petitioner intended to avail an educational loan, she requested the respondent University to issue a certificate certifying that she had passed the II Semester examination. Accordingly, the respondent issued a certificate dated 15.03.2011 certifying that the petitioner had passed all the subjects in the II Semester examination held in December 2010. However, despite the said certificate and the corresponding results being reflected on the University's website, the respondent failed to issue the original II Semester mark statement to the petitioner.

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4. The learned counsel further submitted that the respondent also failed to issue the II Semester mark statement, the VI Semester mark statement, the Provisional Certificate, and the Degree Certificate relating to the M.E. (Computer Science) Part-Time course for the academic years 2009–2012. Consequently, the petitioner filed W.P.(MD) No.13582 of 2013 before this Court seeking issuance of

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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the aforesaid certificates. By order dated 28.01.2014, this Court directed the respondent to issue the said certificates within one week. Challenging the said order, the respondent preferred W.A.(MD) No.962 of 2014, which was subsequently dismissed as withdrawn.

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5. Thereafter, the petitioner initiated contempt proceedings in Cont.P.(MD) No.529 of 2014. During the pendency of the contempt petition, the respondent furnished the II Semester mark statement and the other certificates. However, according to the petitioner, the II Semester mark statement issued by the respondent was not genuine and did not reflect her actual result. Aggrieved by the issuance of the said mark statement, the present writ petition has been filed.

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6. The learned counsel appearing for the petitioner contended that the petitioner had already been issued a certificate dated 15.03.2011 certifying that she had passed all the subjects in the II Semester examination. However, while issuing the mark statement pursuant to the earlier proceedings, the respondent intentionally showed the petitioner as having failed in one subject, namely CS9152 – Database Technology, which is contrary to the earlier certificate issued

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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by the University. Therefore, the learned counsel prayed for appropriate directions.

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7. The respondent has filed a detailed counter affidavit. The relevant averments contained therein are as follows:

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“2. It is submitted that the petitioner was admitted to the M.E. (Part-Time) Degree Programme during the academic year 2009-2010 in the erstwhileAnna University of Technology, Tiruchirappalli. The official academic records unambiguously reveal that the petitioner has not successfully completed one subject in the II Semester, namely CS 9152-Data Base Technology. Unless and Until this arrear paper is cleared, the petitioner is ineligible for conferment of the degree or issuance of the provisional certificate.

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3. It is humbly submitted that the alleged certificate dated 15.03.2011 purportedly issued in the name of the Dean of Anna University of Technology, Tiruchirappalli, is wholly unauthorised, without jurisdiction, and contrary to statutory procedure. Under the statutes, only the Controller of Examinations is empowered to issue academic certificates, and not the Dean. The impugned document, therefore, lacks validity

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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in law and cannot confer any right on the petitioner.

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4. It is humbly submitted that the respondent University further submits that the Director, Centre for Student Affairs of erstwhile Anna University of Technology, Tiruchirappalli, lodged a complaint dated 29.06.2012 against M/s. MRM Xerox Centre for issuing forged bonafide certificates purporting to emanate from the University. The said complaint was duly acknowledged by the Sub-Inspector of Police, Mandaiyur Police Station, vide CSR No.67/2012 dated 03.07.2012, culminating in the registration of FIR No.46/2012 dated 08.08.2012. Although the said complaint was subsequently withdrawn, the very initiation of criminal proceedings evidences the existence of a racket in forged certificates. In all likelihood, the certificate relied upon by the petitioner has originated from such unauthorised sources and is nothing but a forged document.

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5. It is humbly submitted that the respondent University submits that academic degrees are conferred only upon fulfillment of prescribed conditions and successful completion of all subjects. The petitioner, having failed one core subject, is not entitled to claim issuance of provisional or degree certificates. The plea of the petitioner is therefore legally

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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untenable and amounts to attempt to secure relief by misrepresentation and suppression of material facts.

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6. It is respectfully submitted that the University harbours mala fides against the petitioner The withholding of the degree certificate is solely due to her own default in not clearing the arrear paper. The University, being a statutory body, is duty-bound to maintain academic integrity and cannot under any circumstances, issue certificates contrary to records.”

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8. On verification of the academic records, it was found that the petitioner had not successfully completed one paper in the II Semester, namely **CS9152 –

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Database Technology. Unless and until the said arrear paper is cleared, the petitioner is not eligible for conferment of the M.E. Degree or issuance of the Provisional Certificate. It is further stated that Anna University had lodged a complaint on 29.06.2012 against MRM Xerox Centre alleging that forged bonafide certificates purporting to have been issued by the University were being fabricated. The complaint was registered in Crime No.46 of 2012 on 08.08.2012. Though the complaint was subsequently withdrawn, the respondent contends that

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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the initiation of criminal proceedings itself revealed the existence of a racket involving forged University certificates.

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9. According to the respondent, the certificate relied upon by the petitioner appears to have originated from such unauthorized sources and is, therefore, a forged document. The respondent further contends that several documents produced by the petitioner are suspected to be forged and that the genuineness of those documents is the subject matter of investigation by the law enforcing agency. Such disputed questions of fact can be adjudicated only in the criminal proceedings and not in the present writ petition.

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10. On a perusal of the pleadings and the materials placed on record, it is evident that the petitioner relies upon certain certificates allegedly issued by the respondent University, whereas the respondent disputes their genuineness and specifically alleges that they are forged documents. The respondent has also referred to the criminal proceedings initiated in relation to the alleged issuance of forged University certificates and contends that the documents relied upon by the petitioner are connected with the said allegations.

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11. The principal issue involved in the present writ petition is whether the certificates relied upon by the petitioner are genuine or forged. Such an issue

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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involves serious disputed questions of fact requiring appreciation of evidence, which cannot be undertaken in exercise of the extraordinary jurisdiction under Article 226 of the Constitution of India. The genuineness of the documents relied upon by the petitioner can be determined only by the competent criminal court or any other forum before which the issue is pending.

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12. In view of the above, this Court is not inclined to adjudicate the disputed questions of fact involved in the present writ petition. However, liberty is granted to the petitioner to work out her remedies before the appropriate forum after the conclusion of the criminal proceedings or upon the competent authority rendering its findings regarding the genuineness of the documents relied upon by the petitioner.

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13. Accordingly, the Writ Petition stands disposed of. No costs. Consequently, the connected miscellaneous petition is closed.

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01.07.2026

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NCC : Yes / No Index : Yes / No TSG

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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The Registrar, Anna University, Guindy, Chennai.

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https://www.mhc.tn.gov.in/judis

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W.P(MD)No.7932 of 2017

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M.DHANDAPANI, J.

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TSG

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W.P(MD)No.7932 of 2017

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01.07.2026

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11/11

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https://www.mhc.tn.gov.in/judis

Procedural history

How this case reached the court

AI extract

Order under challenge
Original II Semester mark statement issued by the respondent (Registrar, Anna University) to the petitioner, which the writ petition seeks to quash as not genuine.¶17
Registrar, Anna University, Guindy, Chennai
Prior proceeding
Respondent issued a certificate dated 15.03.2011 certifying that the petitioner had passed all subjects in the II Semester examination held in December 2010; the original mark statement was nevertheless not issued.¶23
Prior proceeding
Petitioner filed W.P.(MD) No.13582 of 2013 before this Court seeking issuance of the pending mark statements and certificates.¶24
Prior proceeding
By order dated 28.01.2014 in W.P.(MD) No.13582 of 2013, this Court directed the respondent to issue the said certificates within one week.¶28
Prior proceeding
Respondent challenged the order dated 28.01.2014 in W.A.(MD) No.962 of 2014, which was subsequently dismissed as withdrawn.¶28
Prior proceeding
Petitioner initiated contempt proceedings in Cont.P.(MD) No.529 of 2014; during pendency the respondent furnished the II Semester mark statement and other certificates, which the petitioner alleged were not genuine and did not reflect her actual result.¶29
Prior proceeding
Per respondent's counter affidavit: the Director, Centre for Student Affairs of erstwhile Anna University of Technology, Tiruchirappalli, lodged a complaint dated 29.06.2012 against M/s. MRM Xerox Centre for issuing forged bonafide certificates purporting to emanate from the University.¶42
Prior proceeding
Complaint duly acknowledged by the Sub-Inspector of Police, Mandaiyur Police Station, vide CSR No.67/2012 dated 03.07.2012, culminating in registration of FIR No.46/2012 dated 08.08.2012.¶42
Prior proceeding
The criminal complaint was subsequently withdrawn; respondent contends that the very initiation of criminal proceedings evidenced the existence of a racket in forged certificates, and that the petitioner's certificate likely originated from such unauthorised sources.¶42

Parimala, D/O.T.Nedumaran, v. the Registrar

Case brief

What is this about?

What did the court decide?

Parimala, D/O.T.Nedumaran, v. the Registrar

Case brief

What is this about?

What did the court decide?

Why is it important?

What the court decided

Issues for consideration

Statutes considered

Procedural history

Parties & counsel

Coram

Case details

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