Court rules that false FIR cannot be a basis for denying public employment if investigation concludes allegations are baseless.
Jaipur, May 18, 2026 - In a significant judgment, the Rajasthan High Court has reinforced the principle that a candidate cannot be denied a government appointment solely based on an FIR if the investigation concludes that the allegations are false. The judgment was delivered by Justice Arun Monga in the case of Lal Chand v. State of Rajasthan, addressing the arbitrary denial of a government post due to a false FIR.
The petitioner, Lal Chand, was a successful candidate for the post of Physical Training Instructor (PTI) Grade-III, following an advertisement by the State Government in June 2022. However, his appointment was stalled due to an FIR filed against him under serious charges, including those under the Indian Penal Code and the SC/ST Act. The FIR was lodged after the recruitment result was declared, leading to Lal Chand's exclusion from joining his appointed position.
The High Court noted that a thorough investigation had resulted in a negative final report, affirming the allegations in the FIR as false and driven by personal vendetta. Justice Monga emphasized that once a candidate has been exonerated through a negative final report, the basis for considering them ineligible under the government’s character verification circular dated December 4, 2019, is nullified.
The court interpreted the circular, highlighting that its disqualification clauses apply only to ongoing investigations or convictions, not to cases where investigations have cleared a candidate of any wrongdoing. The judgment underscored that denying employment in such circumstances constitutes a violation of Article 14 of the Indian Constitution, which ensures the right to equality and protection against arbitrary treatment.
The court directed the respondents to reconsider Lal Chand's candidacy, ensuring that if he meets all other eligibility criteria, he should be appointed to the position. The ruling stipulates that if the post is unavailable, he should be considered for the next vacancy, albeit without back pay for the period out of service due to the principle of "No Work, No Pay."
This judgment reaffirms the judiciary's role in safeguarding individual rights against arbitrary administrative actions, particularly in cases where individuals are exonerated from false criminal allegations.
Bottom line:-
A candidate cannot be denied appointment to a government post merely on the basis of an FIR if the investigation concludes that the allegations were false, and a negative final report has been filed within the stipulated timeframe.
Statutory provision(s): Article 14 of the Constitution of India, Indian Penal Code, Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, Circular dated 04.12.2019
Lal Chand v. State of Rajasthan, (Rajasthan) : Law Finder Doc id # 2920612
