The Rajasthan High Court has dismissed a batch of petitions seeking quashing of an FIR related to a large-scale conspiracy involving forged educational credentials and impersonation in public examinations, terming the allegations as “grave offences of public importance.”
Justice Sameer Jain, while delivering the verdict in Babu Lal v. State of Rajasthan and connected cases, observed that the findings of the Special Operations Group (SOG) of Rajasthan established a prima facie case against the petitioners. Premature quashing, the Court held, would amount to abuse of the legal process and prejudice the rights of genuine aspirants to public employment.
"This Court finds no merit for interference and quashing of the impugned FIR, as the allegations reveal prima facie cognizable offences under Sections 467, 468, 471, and 120-B IPC... These are grave offences of public importance. If FIRs of such nature are quashed prematurely, it would result in abuse of the legal process," the Court stated.
The case stemmed from the application of a woman for a lecturer's post, claiming she was pursuing post-graduation from Vardhaman Mahavir Open University. Though she was provisionally selected, discrepancies emerged during document verification.
Upon further inquiry, the Rajasthan Public Service Commission (RPSC) sought verification from the university, which led to the unearthing of a broader conspiracy involving forged degrees from Mewar University and impersonation in government exams. The matter was handed over to the SOG for a detailed probe.
An FIR was registered, and further investigation led to the implication of the present petitioners, including a woman, who were accused of being part of the alleged racket.
The petitioners contended that:
Their names were not included in the original FIR.
There was no substantial evidence against them.
Their implication was based solely on speculative inference by SOG.
As young individuals, their careers would be jeopardized if charges were not quashed.
In response, the prosecution argued that:
The petitioners’ names were added post thorough investigation supported by digital and physical evidence.
One petitioner, identified as petitioner no. 3, was seen in video footage impersonating another candidate at the exam centre.
The petitioners had evaded investigation, indicating consciousness of guilt.
The Court noted that:
Even though the petitioners were unnamed in the FIR, they were rightfully implicated post-investigation under due process.
Their abscondence and non-cooperation further pointed to mala fide conduct.
The case did not meet the conditions laid down by the Supreme Court in State of Haryana v. Bhajan Lal, which restricts quashing to the “rarest of rare” instances.
Finding no exceptional grounds, the Court refused to quash the FIR or the charge sheet, and directed the petitioners to fully cooperate with the investigation.
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