Introduction:

The Rajasthan High Court has delivered a significant ruling underscoring the importance of preserving the integrity of public recruitment examinations and the limited scope of judicial interference at the investigation stage. In Pramila v. State of Rajasthan [2026 LiveLaw (Raj) 223], the Court declined to exercise its inherent jurisdiction to quash a First Information Report (FIR) registered against a serving Forest Guard accused of securing public employment through the use of a dummy candidate in a recruitment examination.

The judgment was delivered by Justice Farjand Ali, who observed that allegations involving manipulation of a public examination conducted by a constitutional recruitment body strike at the very foundation of transparency, fairness, and institutional integrity in public employment. The Court held that offences of such a nature cannot be lightly dismissed at the threshold when the material collected during investigation prima facie discloses the commission of cognizable offences.

The case arose out of allegations relating to the Forest Guard Recruitment Examination, 2020. According to the investigating agency, a dummy candidate allegedly appeared in place of the petitioner during the recruitment examination, resulting in her unlawful selection and appointment as a Forest Guard. The allegations were not based merely on suspicion or anonymous complaints but were supported by material gathered during the course of investigation.

The controversy acquired further significance because the petitioner was already serving in a government post when the allegations surfaced. The State also claimed that a separate criminal case involving similar allegations in connection with the Rajasthan Eligibility Examination for Teachers (REET) 2021 was pending against her. The authorities alleged that this fact had not been disclosed during the process of securing the present appointment.

The petitioner approached the Rajasthan High Court under Section 528 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), seeking quashing of the FIR. She argued that the allegations were misconceived and that the investigation was based on an incorrect understanding of the facts. However, the Court was called upon to determine not whether the petitioner was guilty or innocent, but whether the allegations and evidence collected during investigation justified continuation of criminal proceedings.

The judgment is important because it reiterates the principles governing the exercise of inherent powers by High Courts in criminal matters and highlights the judiciary’s commitment to protecting the credibility of public recruitment systems. It also reinforces the proposition that disputed questions of fact requiring evaluation of evidence cannot ordinarily be decided at the stage of quashing proceedings.

Arguments of the Parties:

The petitioner sought quashing of the FIR primarily on the ground that the allegations against her were factually incorrect and did not justify continuation of criminal proceedings. According to her, the prosecution had wrongly linked her with the alleged impersonation that took place during the Forest Guard Recruitment Examination.

A central aspect of her defence was the claim that the alleged dummy candidate was not intended to appear on her behalf. The petitioner argued that the individual in question had allegedly intended to appear in place of her sister and not for her. On this basis, she contended that the investigation was proceeding on a mistaken factual premise and that the allegations connecting her to the impersonation lacked substance.

The petitioner also addressed the allegation regarding concealment of a pending criminal case. The State had asserted that a separate criminal proceeding involving similar accusations connected to the REET Examination 2021 was already pending against her when she secured the Forest Guard post. According to the prosecution, she failed to disclose this information to the authorities.

In response, the petitioner argued that the recruitment forms required disclosure only of previous convictions and not pending criminal cases. Therefore, she maintained that there was no deliberate concealment or misrepresentation on her part. She submitted that compliance with the disclosure requirements must be assessed strictly in accordance with the language of the form and not through subsequent interpretations imposed by the authorities.

The petitioner further contended that the FIR deserved to be quashed because the allegations did not establish her direct involvement in any criminal activity. She urged the Court to exercise its powers under Section 528 BNSS to prevent abuse of the process of law and to protect her from unnecessary criminal prosecution.

The State of Rajasthan strongly opposed the petition and argued that the matter involved serious allegations affecting the credibility of a public recruitment process. According to the State, the investigation had revealed substantial discrepancies indicating impersonation during the examination.

The prosecution pointed out that the photographs and signatures uploaded by the petitioner in the online application form did not match the photographs and signatures appearing on the admit card and examination-related documents. These discrepancies, according to the State, formed an important part of the evidence suggesting that another individual may have appeared in the examination on behalf of the petitioner.

The State also emphasized that the allegations were not based on mere assumptions or conjecture. Instead, they were founded upon documentary evidence and materials collected during the course of investigation by the competent authorities. The investigating agency had undertaken inquiries and gathered relevant material that, according to the prosecution, established a prima facie case warranting further investigation.

With regard to the pending REET case, the State argued that the existence of similar allegations in another recruitment examination was a relevant circumstance that could not be ignored. Although the State did not contend that the pendency of the case itself established guilt, it submitted that the similarity of allegations strengthened the need for a thorough investigation into the present matter.

The prosecution further argued that the petitioner’s defence involved disputed questions of fact. Determining whether the alleged dummy candidate intended to appear for the petitioner or for her sister would require examination of evidence, witness testimony, documentary records, and investigative findings. Such issues, according to the State, could not be adjudicated in proceedings seeking quashing of an FIR.

The State therefore urged the Court to permit the investigation to continue, arguing that premature judicial intervention would hinder the discovery of truth and potentially undermine public confidence in recruitment processes conducted by constitutional bodies.

Court’s Judgment:

After considering the rival submissions and examining the material available on record, the Rajasthan High Court declined to interfere with the investigation and dismissed the petition seeking quashing of the FIR.

Justice Farjand Ali began by emphasizing the seriousness of the allegations. The Court observed that the case did not involve a routine private dispute or a minor criminal allegation. Instead, it concerned an alleged manipulation of a public recruitment examination conducted by a constitutional recruitment authority.

The Court noted that public recruitment examinations occupy a crucial position in the administration of government services. These examinations are intended to ensure that appointments to public posts are made through a transparent, merit-based, and fair process. Any attempt to manipulate such examinations undermines public confidence in governmental institutions and compromises the principles of equality and fairness that form the foundation of public employment.

Accordingly, the Court observed that allegations involving the use of a dummy candidate in a recruitment examination strike directly at the integrity of the selection process. Such allegations cannot be treated casually or dismissed without proper investigation, particularly when they concern appointments to public offices.

A significant aspect of the Court’s reasoning related to the scope of its jurisdiction under Section 528 of the Bharatiya Nagarik Suraksha Sanhita. The Bench reiterated the settled legal principle that while exercising inherent powers to quash criminal proceedings, the Court is not expected to conduct a mini-trial or evaluate the sufficiency of evidence as if determining guilt or innocence.

The purpose of the Court’s inquiry at this stage is limited. The Court must examine whether the allegations contained in the FIR and the material collected during investigation disclose the commission of cognizable offences. If such material exists, the investigation should ordinarily be permitted to proceed.

Applying this principle to the facts of the case, the Court found that the allegations against the petitioner were not based on vague, bald, or omnibus assertions. Rather, they were supported by material collected by the investigating agency during the course of its inquiry.

The Court took note of the prosecution’s assertion that discrepancies existed between the photographs and signatures submitted by the petitioner and those appearing on examination documents. These discrepancies constituted relevant material capable of supporting an inference that further investigation was necessary.

The Court also considered the petitioner’s defence that the alleged dummy candidate had intended to appear for her sister rather than for the petitioner herself. However, the Bench observed that this defence involved factual questions that could only be resolved through proper appreciation of evidence.

The Court stressed that determining the truthfulness of such a defence would require examination of witnesses, scrutiny of documentary records, and assessment of competing versions of events. Such an exercise falls within the domain of investigation and trial rather than proceedings seeking quashing of an FIR.

Justice Farjand Ali categorically held that the High Court cannot undertake a detailed evaluation of evidence while exercising jurisdiction under Section 528 BNSS. To do so would effectively amount to conducting a premature trial, which is impermissible under settled principles of criminal jurisprudence.

The Court further emphasized the broader public interest dimension of the case. Recruitment examinations conducted by constitutional bodies are designed to ensure equal opportunity and merit-based selection. Any allegation suggesting impersonation, fraud, or manipulation affects not only the individuals directly involved but also the legitimacy of the entire recruitment system.

In this context, the Court observed that offences involving public examinations have far-reaching consequences because they erode public trust in governmental institutions. Therefore, allegations of such misconduct deserve careful investigation rather than summary dismissal at the initial stage.

The Bench also recognized that the investigation was being carried out by a specialized agency and that material had already been collected indicating the possible commission of cognizable offences. In such circumstances, judicial restraint was warranted to allow the investigative process to reach its logical conclusion.

The Court concluded that the material available on record disclosed sufficient grounds to continue the investigation. Since the allegations revealed a prima facie case requiring further inquiry, there was no justification for invoking the extraordinary power of quashing the FIR.

Accordingly, the petition was dismissed.

The judgment serves as an important reminder that the integrity of public recruitment processes must be zealously protected. It reaffirms that courts exercising inherent jurisdiction should not interfere with criminal investigations merely because an accused person offers an alternative explanation of events. Where allegations are supported by material collected during investigation and disclose the commission of cognizable offences, the proper course is to permit the investigation and trial process to proceed in accordance with law. The decision thus strengthens the legal framework aimed at safeguarding transparency, fairness, and public confidence in recruitment examinations conducted by constitutional authorities.