Court Upholds Investigation into Alleged Use of Unfair Means in Forest Guard Recruitment Examination
In a significant ruling, the Rajasthan High Court, presided over by Justice Farjand Ali, dismissed a petition filed by Pramila seeking to quash an FIR registered against her for alleged impersonation and the use of unfair means in the Forest Guard Recruitment Examination, 2020. The case, which has brought to light serious allegations of manipulation in public recruitment processes, underscores the judiciary's stance on maintaining transparency and fairness in public employment.
The FIR, numbered 56/2025, was lodged at the Special Police Station, ATS & SOG, Rajasthan, charging Pramila under various sections of the Indian Penal Code, including sections 419, 420, 467, 468, 471, and 120B, as well as sections of the Rajasthan Public Examination (Prevention of Unfair Means) Act. The investigation, conducted by the Special Operations Group (SOG), revealed that a dummy candidate allegedly appeared in the examination on behalf of Pramila, facilitating her unlawful selection to the post of Forest Guard.
Detailed findings from the investigative report highlighted discrepancies between the photographs and signatures on Pramila's online application form and those on the examination documents. This discrepancy, coupled with a prior FIR (No. 125/2021) against her for similar allegations in the REET Examination, 2021, suggested a pattern of unfair practices. Furthermore, it was found that Pramila had allegedly concealed this previous criminal case during her police verification.
The court, upon reviewing the material collected during the investigation, emphasized that the allegations were not based on vague assertions but were supported by substantial evidence. Justice Ali noted that the exercise of the court's inherent jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023, should be approached with caution, especially when the investigation into cognizable offences is ongoing.
The defense put forth by Pramila, claiming that the dummy candidate was meant to appear on behalf of her sister, was deemed a matter requiring detailed factual adjudication, inappropriate for resolution at this preliminary stage. The court asserted that the investigation should continue, given the prima facie evidence indicating cognizable offences, and dismissed the petition for quashment of the FIR.
This ruling reinforces the judicial system's commitment to upholding the integrity of public recruitment examinations and deterring malpractice. The case will proceed with the ongoing investigation to ensure accountability and justice.
Bottom line:-
Quashment of FIR - Allegations of impersonation and adoption of unfair means in public recruitment examination cannot be lightly brushed aside, particularly when investigation is conducted by a specialized agency and prima facie material exists to substantiate cognizable offences.
Statutory provision(s):
Bharatiya Nagarik Suraksha Sanhita, 2023 Section 528, IPC Sections 419, 420, 467, 468, 471, 120B, Sections 3, 6, 7, 10 of the Rajasthan Public Examination (Prevention of Unfair Means) Act
Pramila v. State of Rajasthan, (Rajasthan) : Law Finder Doc id # 2918735