New Delhi: The Supreme Court has directed the Central Bureau of Investigation (CBI) to investigate the authenticity of a Bachelor of Commerce degree claimed by advocate Naresh Dilawari, after Magadh University declared the certificate forged and not issued by the institution.
A bench comprising Justice Manoj Misra and Justice Ujjal Bhuyan delivered the order on September 15, 2025, in Civil Appeal No. 4651/2025 (Naresh Dilawari vs. Charanjit Singh Oberoi), following serious concerns raised about the genuineness of the petitioner’s academic credentials.
The controversy emerged when the Bar Council of Punjab and Haryana filed an interlocutory application seeking permission to place additional documents on record. Among these documents was a crucial letter from the Controller of Examinations, Magadh University, Bodh Gaya.
The court noted, “Annexure A3 to the above interlocutory application is a letter issued by the Controller of Examinations, Magadh University, Bodh Gaya, wherein it is stated that the copy of the mark-sheet and degree certificate in favour of Naresh Dilawari (Roll-PAT-16335, Regd No. 2870/88, BCom. Accounts (Hons.), Examination 1991), upon verification, was found forged and not issued from the University.”
In response to the university’s findings, the court had earlier directed the petitioner to file photocopies of his degrees in Commerce and Law. Pursuant to this direction, Dilawari submitted a photocopy of his BCom (Honours) degree allegedly obtained from Magadh University in August 1991.
The respondent’s counsel drew the court’s attention to the university’s categorical denial of issuing the degree, emphasizing that both the mark-sheet and degree certificate were declared fake and forged by the institution’s Controller of Examinations.
Dilawari’s defense centered around claims that university records were damaged, making verification difficult. The court observed, “The petitioner, on the other hand, has invited our attention to Annexure A-2 to the said I.A No. 161167 of 2025 to canvass that the records of the University were torn and, therefore, the degree may not be verifiable from the available records.”
However, the Supreme Court found the gravity of the allegations warranted a thorough investigation by the premier investigating agency. The bench stated, “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 BCom examination from Magadh University in the year 1991 is genuine or forged.”
The court has set a strict timeline for the investigation, directing that a copy of the order be sent to the Director of CBI, Delhi, who must depute an officer to investigate the matter and submit a report by November 30, 2025.
The matter has been scheduled for further hearing on December 9, 2025, along with the CBI’s investigation report.
Case Title: Naresh Dilawari vs. Charanjit Singh Oberoi