Introduction:

In the case of Babu Lal v. State of Rajasthan & connected petitions [2025 LiveLaw (Raj) 227], the Rajasthan High Court, through Justice Sameer Jain, dismissed a batch of petitions filed by three accused—including a woman—seeking quashing of an FIR that alleged their involvement in a large-scale conspiracy entailing fabrication of educational credentials, impersonation during public examinations, and forging of degree certificates to secure government employment, holding that the allegations revealed grave offences affecting public importance and the integrity of the recruitment process, and that premature quashing of the FIRs would prejudice the rights of genuine aspirants. The case arose when a candidate provisionally selected for the post of lecturer claimed to be pursuing her post-graduation from Vardhaman Mahavir Open University, but during document verification, significant discrepancies in her academic records were discovered. The Rajasthan Public Service Commission (RPSC) sought verification from the university, which triggered an investigation revealing a widespread conspiracy involving mass fabrication and sale of fake degrees from Mewar University, coupled with impersonation in government recruitment exams. The probe was handed over to the Special Operations Group (SOG), Rajasthan, which registered an FIR against the applicant and, during further investigation, implicated the petitioners based on what the prosecution claimed was robust digital and physical evidence linking them to the conspiracy.

Arguments:

Representing the petitioners, their counsel argued that the petitioners were neither named in the original FIR nor was there substantial evidence justifying their addition to the case; the linkage was speculative, merely based on inference, and lacking direct proof of involvement. Counsel emphasized that the petitioners were young individuals whose careers and reputations would suffer irreparable harm if subjected to a criminal trial based on unsubstantiated allegations, amounting to misuse of the criminal justice process. The petitioners contended that quashing of FIRs was essential to protect their future from being destroyed on account of a flawed investigation leading to their wrongful implication. Conversely, the State, represented by the AAG and SOG officials, argued that although the petitioners’ names were not in the original FIR, they surfaced during an intensive investigation corroborated by digital video recordings, call detail records, and other forensic evidence which established their participation in the conspiracy. The State pointed out that petitioner no. 3 was captured on CCTV footage appearing in the examination under a false identity, conclusively tying him to the impersonation allegation. It was further argued that the petitioners evaded arrest for an extended period, avoiding cooperation with investigating authorities, indicating a consciousness of guilt and attempt to obstruct justice. The State maintained that a prima facie case was clearly made out under Sections 467, 468, 471, and 120-B IPC, dealing with forgery, use of forged documents, and conspiracy, and that quashing the FIR at this stage would not only obstruct the due process of law but also severely prejudice the rights of genuine candidates who suffered due to the scam. The State placed reliance on the Supreme Court’s judgment in State of Haryana v. Bhajan Lal laying down the principle that High Courts should exercise their extraordinary powers to quash FIRs only in the rarest of rare circumstances—when allegations do not disclose a cognizable offence even if accepted on their face value, or where allegations are manifestly absurd, or where there is a clear indication of malafide or ulterior motive in the registration of the FIR. The prosecution asserted that none of these conditions were fulfilled in the present case as the allegations, accepted at face value, constituted serious cognizable offences, and there was no evidence of malafide in the registration of the case. Justice Jain, after meticulously examining the investigation record, the factual report furnished by the Superintendent of Police, SOG Ajmer, and hearing submissions of both sides, held that the findings and material collected during the investigation disclosed sufficient grounds for the registration of cognizable offences and the petitioners’ alleged involvement in a conspiracy of significant public importance, as it directly affected the sanctity of the government recruitment process.

Judgement:

The Court noted that prima facie material established petitioner no. 3’s impersonation in the exam as evidenced by the digital video retrieved from the examination centre, corroborating the allegations beyond speculative inference. Justice Jain underscored that the mere fact that petitioners were not named in the original FIR did not render their subsequent implication illegal if their names emerged during investigation based on credible evidence, and there was no infirmity or procedural irregularity in the investigation warranting quashing. The Court also rejected the plea of youthful age advanced by the petitioners, observing that crimes affecting the credibility of public recruitment systems have far-reaching implications for society, and quashing such FIRs would embolden unscrupulous elements to undermine merit-based selection, harming legitimate aspirants’ rights. The High Court emphasized that the gravity of allegations involving impersonation and forgery in examinations that decide future careers of countless individuals elevates these offences to matters of public importance, requiring rigorous investigation and trial rather than premature quashing at the threshold. Reiterating the principle laid down in Bhajan Lal, the Court ruled that the present case did not fall into any exceptional category justifying invocation of inherent powers under Section 528 BNSS to quash the FIR or charge sheet. Justice Jain dismissed the quashing petitions, directing the petitioners to cooperate fully with the investigation and participate in legal proceedings as required, reinforcing the message that tampering with public recruitment processes through fraudulent means will not be tolerated, and courts will ensure comprehensive investigation and prosecution of those undermining the sanctity of examinations crucial for public employment.