The Central Bureau of Investigation (CBI) has found prima facie evidence of cognizable offences including forgery and fabrication of public documents in connection with the B.Com degree produced by an advocate, the Supreme Court has recorded.

A bench of Justice Ujjal Bhuyan and Justice Atul S. Chandurkar, in an order passed on August 17, 2026, recorded that the CBI had submitted a status report pursuant to the Court's September 15, 2025 direction to investigate whether the degree relied upon by Naresh Dilawari was genuine or forged.

The Court noted that the CBI's report, submitted in a sealed cover and opened in Court, stated that:

“prima facie, commission of cognizable offences of forgery, fabrication of public documents etc., have been made out against the appellant-in-person and other unknown persons.”

The proceedings arise from disciplinary action against Dilawari concerning the genuineness of his educational qualifications. Dilawari has been an advocate since 2001 and obtained his licence to practise from the Bar Council of Punjab and Haryana.

The matter had earlier reached the Supreme Court after the Bar Council of Punjab and Haryana suspended Dilawari's right to practise for two years by an order dated December 20, 2021, pursuant to a complaint against him.

Dilawari challenged the suspension before the Disciplinary Committee of the Bar Council of India.

On January 16, 2025, the BCI Disciplinary Committee directed the Bar Council of Punjab and Haryana to verify the genuineness of his educational qualifications by conducting an inquiry. Pending conclusion of the inquiry, his licence was directed to remain suspended.

The authenticity of Dilawari's B.Com degree had come under scrutiny before the Supreme Court during an earlier hearing in the matter.

The Court had taken note of a communication issued by the Controller of Examinations of Magadh University, Bodh Gaya, stating that the mark sheet and B.Com degree standing in Dilawari's name for the 1991 examination were “forged and not issued from the University.”

The Court had thereafter directed Dilawari to produce photocopies of the degrees on the basis of which he claimed to have graduated in Commerce and Law.

Following the direction, Dilawari produced a photocopy of his B.Com (Hons.) degree certificate for the 1991 examination. Counsel appearing for the respondent, however, drew the Court's attention to another annexure which reiterated the University's position that the documents were fabricated.

Dilawari had sought to explain the discrepancy by stating that the University's records had been torn or were missing, which, according to him, could have resulted in difficulties in verifying the authenticity of the degree.

The Court did not accept that explanation as sufficient to resolve the issue and, on September 15, 2025, directed the CBI to investigate the matter.

The Court had observed:

“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.”

In its August 17 order, the Supreme Court also took note of subsequent disciplinary proceedings before the Bar Council authorities.

The Bar Council of Punjab and Haryana produced before the Court a notification dated August 5, 2025, stating that an inquiry had been conducted pursuant to the directions of the BCI Disciplinary Committee.

Thereafter, pursuant to a direction issued by the BCI Disciplinary Committee on July 6, 2025, Dilawari's name was removed from the Roll of the Bar Council of Punjab and Haryana, with a further direction that he surrender his licence and related documents.

Appearing in person before the Supreme Court, Dilawari challenged the jurisdiction of the BCI Disciplinary Committee to direct the Bar Council of Punjab and Haryana to conduct a fresh inquiry and thereafter remove his name from the roll. He contended that the BCI Disciplinary Committee had exceeded its jurisdiction in issuing such directions.

The Supreme Court did not examine the merits of that challenge in the present proceedings. The bench observed that Dilawari could challenge the legality and validity of the August 5, 2025 notification in an appropriate proceeding before the appropriate forum.

The Court further directed that if such proceedings were instituted within 30 days from the date of its order, the issue of limitation would not come in the way of consideration of the challenge.

Cause Title: NARESH DILAWARI VERSUS CHARANJIT SINGH OBEROI

Click here to read the order

Thousands Of Fraudulent Lawyers, BCI Won't Do Anything; Need CBI To Verify Law Degrees : CJI Surya Kant