Facts of the
Case
The complainant, Sri C. Easwaramoorthy, IPS,
Superintendent of Police, Central Bureau of Investigation, Anti-Corruption
Branch, Chennai, filed a complaint against the respondent, CA T.M.
Jeyachandran, arising out of investigation in CBI Case No. RC 3(A)/2009. The
investigation related to Dr. V.V. Sairam Babu, Port Health Officer, Chennai Sea
Port, who was alleged to have amassed assets disproportionate to his known
sources of income to the tune of ₹2,41,61,809 during the period 01.01.1999 to
10.01.2009.
It was alleged that the respondent entered into a
criminal conspiracy with Dr. V.V. Sairam Babu and prepared false and fabricated
documents, including a document titled “Memorandum for Mutual Co-Operation”
dated 22.09.2009, falsely shown as executed on 01.08.2002, to create a
fictitious source of income of ₹55,00,000 in the name of the wife of the public
servant. The document was allegedly routed through another Chartered
Accountant’s system to avoid tracing its origin and was used to mislead the CBI
investigation.
Issues
Involved
Whether the respondent Chartered Accountant was
guilty of “Other Misconduct” under Item (2) of Part IV of the First Schedule to
the Chartered Accountants Act, 1949 for entering into criminal conspiracy and
preparing forged and ante-dated documents to conceal disproportionate assets of
a public servant under investigation by the CBI.
Petitioner’s
Arguments
The complainant department contended that the
respondent deliberately prepared false and fabricated documents to account for
unexplained assets of the accused public servant and conspired to obstruct a
lawful CBI investigation. It was submitted that forensic examination, witness
statements, and seizure of computer systems conclusively established that the
respondent created and transmitted the forged document, which was then printed
and handed over to the accused. The complainant further relied on the pendency of
criminal prosecution against the respondent under Sections 120B, 465, 467, 468
and 471 of the Indian Penal Code.
Respondent’s
Arguments
The respondent denied having created the impugned
document and contended that the file was planted on his office computer after
seizure by the CBI. He relied heavily on the Forensic Lab Report to argue that
file timestamps did not conclusively prove creation on his system and that his
office computer had been tampered with. The respondent further argued that the
document was allegedly prepared by an advocate and that his role was limited to
forwarding an email without knowledge of its contents. He also questioned the
credibility of witness statements and alleged procedural lapses by the
investigating agency.
Court Order
/ Findings
The Board of Discipline examined the forensic
evidence, witness testimonies, submissions of the parties, and the sequence of
events. The Board noted that Witness No. 2 categorically stated that the
respondent sent the document to his system for printing and handing over to the
accused, and that forensic testing of the witness’s system corroborated the
transmission of the document from the respondent.
The Board rejected the respondent’s plea of
tampering and planting of evidence, observing that no conclusive proof was
produced to support such allegations. The Board further held that the
respondent’s explanations were inconsistent and unsupported by evidence. On
appreciation of material on record, the Board concluded that the respondent had
entered into a criminal conspiracy and had created false and fabricated
ante-dated documents with the intent to conceal disproportionate assets and
impede a CBI investigation.
Important
Clarification
The Board clarified that preparation or
facilitation of forged or ante-dated documents to mislead investigating
agencies constitutes grave professional misconduct. A Chartered Accountant is
expected to uphold the highest standards of integrity, and any involvement in
criminal conspiracy or obstruction of justice attracts strict disciplinary
action irrespective of pendency of criminal proceedings.
Final
Outcome
The Board of Discipline, ICAI, held that CA T.M.
Jeyachandran was GUILTY of Other Misconduct under Item (2) of Part IV of
the First Schedule to the Chartered Accountants Act, 1949. In exercise of
powers under Section 21A(3), the Board ordered removal of his name from the
Register of Members for a period of 30 days, by order dated 25.09.2024,
pursuant to its findings dated 27.08.2024.
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