[2025:RJ-JP:48946] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR S.B. Criminal Miscellaneous Bail Application No. 12352/2025 Sourav Kalal S/o Sohan Kalal, Aged About 28 Years, R/o Kalalwara, Ward No. 3, Police Station Bhugda, District Banswara, Presently P.t.i. Government Upper Primary School Undavenla, District Banswara. (At Present Confined In Central Jail Jaipur). ----Petitioner Versus State Of Rajasthan, Through Pp ----Respondent Connected With S.B. Criminal Miscellaneous Bail Application No. 15076/2025 Pradeep Kumar Sharma S/o Amarchandra Sharma, Aged About 41 Years, R/o Ward No. 25, Bukalsar Bas, Sardar Shahar, Police Station Sardar Shahar, District Churu, Rajasthan. (Accused Petitioner Presently Confined In Central Jail Jaipur). ----Petitioner Versus State Of Rajasthan, Through Pp ----Respondent For Petitioner(s) : Mr. Tushar Panwar with Mr. Rohit Kumar Mahra & Mr. Sumit Patel Mr. Vedant Sharma For Respondent(s) : Mr. Rhishi Raj Singh Rathore, PP Mr. Shiv Kumar, SOG Jaipur HON'BLE MR. JUSTICE SAMEER JAIN Order 1. Arguments Concluded on: 02.12.2025 2. Judgment Reserved on: 02.12.2025 3. Full Judgment/Operative Part Pronounced: Full Judgment 4. Pronounced on: 6.12.2025 [2025:RJ-JP:48946] (2 of 7) [CRLMB-12352/2025] In CRLMB No. 12352/2025 1. The instant bail application has been filed under Section 483 BNSS on behalf of accused-applicant. The accused-applicant was arrested in connection with FIR No. 14/2025 registered at Police Station SOG Jaipur for the offence(s) under Sections 420, 467, 468, 471 and 120B of IPC. 2. Learned counsel appearing for the applicant had submitted that the applicant is a young man aged about 28 years and is presently a student pursuing his career for public employment. It was contended that the applicant has no criminal antecedents whatsoever and has enjoyed a clean record throughout. Learned counsel further submitted that the applicant has been in continuous judicial custody since 20.08.2025, and prolonged incarceration at this pre-trial stage would gravely prejudice his studies and future prospects. It was also argued that the University concerned i.e. J.S. University has not raised any objection with respect to the genuineness of the signature appearing on the marksheet/degree in question, thereby diluting the very foundation of the allegations levelled against the applicant. 3. Learned counsel further asserted that the applicant is the sole bread-earner of his family, and his continued detention has resulted in severe financial and emotional hardship to the dependents who solely rely upon him for sustenance. It was submitted that the investigation, in so far as the applicant is concerned, stands substantially completed and no further custodial interrogation is warranted as the charge sheet in the instant matter is already filed on 11.11.2025. Hence, it was [2025:RJ-JP:48946] (3 of 7) [CRLMB-12352/2025] prayed that the applicant may be enlarged on bail in the interest of justice. 4. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application. However, does not dispute the fact that the applicant has no criminal antecedents and that he has remained in custody since 20.08.2025. 5. Having considered the overall facts and circumstances of the case, the nature of allegations, the applicant’s age, his status as a student with no criminal antecedents, the absence of any objection from the University regarding the disputed signature, and the fact that the investigation is substantially complete and charge sheet is already filed, this Court is of the opinion that further custodial detention of the applicant is not warranted. The possibility of the trial taking considerable time to conclude also cannot be ignored. 6. Accordingly, the present bail application is hereby allowed. It is ordered that accused-applicant Sourav Kalal S/o Sohan Kalal shall be enlarged on bail provided he furnishes a personal bond of Rs.50,000/- with two sureties of Rs.25,000/- each to the satisfaction of learned trial Judge for his appearance before the court concerned on all the dates of hearing as and when called upon to do so. I n CRLMB No. 15076/2025 1. The instant bail application has been filed under Section 483 BNSS on behalf of accused-applicant. The accused-applicant was arrested in connection with FIR No. 14/2025 registered at Police Station SOG Jaipur for the offence(s) under Sections 420, 467, 468, 471 and 120B of IPC. [2025:RJ-JP:48946] (4 of 7) [CRLMB-12352/2025] 2. Learned counsel appearing on behalf of the accused- applicant submitted that the allegation pertains to issuance of B.P.Ed. degrees in backdates under the name of J.S. University, Shikohabad, Uttar Pradesh, thereby rendering them forged. It was argued that at the time of the applicant’s arrest on 18.08.2025, he had merely been released from judicial custody in connection with an erstwhile FIR, and that the present arrest is founded solely on certain electronic evidence (hard-disk) seized during the course of investigation in FIR No. 13/2024. 3. It was further contended that the prosecution alleges that one Suman Bhari, wife of co-accused Mandeep Kanwar, used the purportedly forged and backdated degree to participate in the Physical Education Teacher Recruitment, 2022. Learned counsel submitted that, significantly, on the date of registration of the present FIR, the applicant was already in judicial custody, and subsequently came to be enlarged on bail by the Hon’ble Supreme Court vide order dated 14.08.2025 in SLP (Crl.) No. 10338/2025 titled Pradeep Kumar Sharma vs. State of Rajasthan. 4. It was further urged that the applicant had functioned merely as a facilitator/broker for J.S. University, and that his arrest in the present matter is solely predicated on the hard-disk allegedly recovered in the earlier FIR, without there being any independent or cogent incriminating evidence in relation to the instant case. It was also contended that the offences alleged are triable by a Magistrate, and that the present proceedings are a quintessential instance of an “insurance arrest”. 5. Per contra, learned Public Prosecutor had vehemently opposed the instant bail application, and had submitted that the [2025:RJ-JP:48946] (5 of 7) [CRLMB-12352/2025] applicant is habitual of committing such offence. It was also informed that the applicant has criminal antecedents of similar nature registered against him. It was further contended that the investigation reveals a systematic racket in issuance of forged degrees, causing grave prejudice to the sanctity of public recruitment. It was submitted that the digital evidence seized, including the hard-disk, contains incriminating material (list of candidates with certain data written in adjacent columns) linking the applicant to preparation and backdating of forged B.P.Ed. degrees for illegal monetary gain. 6. Having heard the submissions made by the learned counsel for the parties, upon an assiduous scanning of record and taking note of the material facts and circumstances of the instant matter, this Court is of a view that the allegations against the applicant relate to forgery of educational degrees and enabling candidates to fraudulently participate in public recruitment examinations. The Hon’ble Supreme Court has consistently held that offences affecting the purity of public employment, public trust, and integrity of institutional processes are serious economic offences , where grant of bail must be considered with greater caution. In State of Gujarat v. Mohanlal Jitamalji Porwal, (1987) 2 SCC 364, the Supreme Court observed that economic offences “pose a serious threat to the financial and social fabric of the nation” and must be viewed differently for bail purposes. Further, in Nimmagadda Prasad v. CBI, (2013) 7 SCC 466, it was held that where allegations reveal a systematic fraud involving public institutions, “the consequences are deleterious”, and courts must be slow in granting bail. [2025:RJ-JP:48946] (6 of 7) [CRLMB-12352/2025] 7. The act of forgery of educational degrees and using them to gain public employment has been held to be a grave societal offence as such conduct undermines meritocracy and is a fraud upon the public at large. In the matter at hand the material seized during investigation, particularly digital evidence, cannot be lightly disregarded at this stage. Further it can be noted that the applicant’s role as a facilitator/broker, as alleged, goes to the root of the conspiracy. Forgery of educational credentials affects the credibility of public recruitment, and the modus operandi prima facie indicates an organised network, requiring thorough custodial interrogation. 8. At this stage of investigation, this Court finds that the accusations are serious in nature, supported by digital evidence requiring forensic examination, and the applicant’s release may prejudice the ongoing investigation, particularly regarding identification of other beneficiaries and destruction or tampering of electronic evidence; that the applicant’s bank account reflects transactions around the same period; that the applicant has criminal antecedents registered against him (reproduced as per the impugned bail dismissal order dated 04.10.2025 at the end of this paragraph); that in view of the nature and gravity of the offence, the material collected so far, the stage of investigation, and in light of the judicial precedents cited hereinabove, and the fact that the Hon’ble Supreme Court had granted bail to the applicant in an erstwhile case merely on the basis of period of custody and the same has no relevance with the matter at hand, this Court is not inclined to extend the benefit of bail to the [2025:RJ-JP:48946] (7 of 7) [CRLMB-12352/2025] accused-applicant at this stage. List of the criminal antecedents is reproduced herein under:- क०स० मु०नं० व दि नांक धारा पुदिस थाना चा्ቌशीट नं० 01. 13/2024 08.04.2024 420, 467, 468, 471, 120 बी भा. ं.सं. व 66 डी आईटी ए्ሴ 2008 एसओ्ቌी, रा्ቌ्ቝान ्ቌयपुर 09/2024, 04.07.2024 02. 56/2024 08.08.2024 420, 467, 468, 471, 120 बी भा. ं.सं. व 3, 4, 6, 10 रा्ቌ० साव० परी्ቌा ( भቔኍ# के अनुदिचቔኍ साधनों की रोकथाम के अ्ቖुपाय) अदिधदिनयम 2022 एसओ्ቌी, रा्ቌ्ቝान ्ቌयपुर -- 9. Accordingly, the present bail application stands dismissed. 10. A copy of this order be placed in the connected application. (SAMEER JAIN),J Pooja/61-62