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2026:CGHC:88
AFR Reserved on : 04.11.2025 Delivered on : 02.01.2026 HIGH COURT OF CHHATTISGARH AT BILASPUR WPS No. 1205 of 2025 1 - Devendra Rajput S/o Nawal Singh Rajput Aged About 33 Years R/o Ward No. 12, Keshtara, P.S. Bemetara, District Bemetara Chhattisgarh. 2 - Pramod Singh S/o Pokhan Singh Aged About 32 Years R/o Village Birampur, Rajputpara, Post And Tahsil Bemetara, District Bemetara Chhattisgarh. 3 - Sunder Lal Ghritlahare S/o Ubaran Das Ghritlahre Aged About 40 Years R/o Village Darri, Post And Tahsil Navagarh, District Bemetara Chhattisgarh. 4 - Chandraprakash S/o Bahorik Lal Sahu Aged About 32 Years R/o Ward No. 4, Kachari Para, District Bemetara Chhattisgarh. 5 - Dhaneshwar Prasad Ghritlahre S/o Ravidas Ghritlahre Aged About 35 Years R/o Village Jhal, Post And Tahsil Bemetara, District Bemetara Chhattisgarh. 6 - Anuradha Baghel D/o Govardhan Baghel Aged About 36 Years R/o Ward No. 7, Temri, District Bemetara Chhattisgarh. 7 - Nimesh Kumar Dhruw S/o Umeram Dhruw Aged About 34 Years R/o Village Amaldiha, Post And Tahsil Narayanpur, District Bemetara Chhattisgarh. 8 - Kamal Kumar Paikra S/o Samar Singh Paikra Aged About 34 Years R/o Village Haranmundi, Post Bakshi, District Korba Chhattisgarh. 9 - Sanjay Kumar Sahu S/o Gopal Prasad Sahu Aged About 37 Years R/o Village Darri, Kishna Vihar, Post And Tahsil Jamnipali, District Korba Chhattisgarh. 10 - Vinita Kujur W/o Rameshwar Prasad Patle Aged About 41 Years R/o Village Urga, Post And Tahsil Kurudmal, District Korba Chhattisgarh. 11 - Kavita Kumari D/o Umashankar Jatashankar Aged About 33 Years R/o Balgi Colony, Ward No. 46, District Korba Chhattisgarh. 12 - Archna Kanwar D/o Ram Singh Kanwar Aged About 34 Years R/o Village Gharipakhna, House No. 17, Post And Tahsil Pondi Uproda, District Korba Chhattisgarh. 2 13 - Harish Kumar Dubey S/o Bhupendra Lal Dubey Aged About 33 Years R/o Village Pali, Post And Tahsil Katghora, District Korba Chhattisgarh. 14 - Mohanlal Purame S/o Mithunram Purame Aged About 35 Years R/o Village Wako, Post And Tahsil Dighwadi, District Rajnandgaon Chhattisgarh. 15 - Rupesh Kumar Sahare S/o Tuka Ram Aged About 34 Years R/o Ward No. 2, House No. 23, Post And Tahsil Bhawsha, District Rajnandgaon Chhattisgarh. 16 - Nitesh Khandelwal S/o Rameshwar Prasad Khandelwal Aged About 47 Years R/o Ward No. 10, Manpur, District Rajnandgaon Chhattisgarh. 17 - Surendra Kumar Ramteke S/o Nameshwar Ramteke Aged About 34 Years R/o Ward No. 7, House No. 30, Palebhatti, District Rajnandgaon Chhattisgarh.
18 - Chumman Lal Komre S/o Shivnath Singh Komre Aged About 34 Years R/o Ward No. 13, Post And Tahsil Manpur, District Rajnandgaon Chhattisgarh. 19 - Dharmendra Kumar Pausarya S/o Sukhdev Ram Pausarya Aged About 35 Years R/o Ward No. 10, Post And Tahsil Kakaipar, District Rajnandgaon Chhattisgarh. 20 - Thakurram Koshma S/o Aktu Ram Kosma Aged About 36 Years R/o House No. 201, Ward No. 9, Charbhata, District Rajnandgaon Chhattisgarh. 21 - Pramod Kumar Baghel S/o Jhikoo Ram Baghel Aged About 39 Years R/o House No. 185, Bettipara, Post And Tahsil Badekilepal, District Bastar Chhattisgarh. 22 - Ramvilas Yalam S/o Baswaiya Yalam Aged About 41 Years R/o Village Pusgudi, Post And Tahsil Baijapur, District Bijapur Chhattisgarh. 23 - Ramdas Markam S/o Dhanatkari Markam Aged About 33 Years R/o Village Karkapal, Post Hatkachora, District Bastar Chhattisgarh. 24 - Doman Singh Thakur S/o Panchu Ram Thakur Aged About 40 Years R/o Ward No. 5, Konta, District Sukma Chhattisgarh. 25 - Prafull Salam S/o Mansingh Salam Aged About 36 Years R/o Village Naimed, Nayapara, Post And Tahsil Bijapur, District Bijapur Chhattisgarh. 26 - Lokhnath Sinha S/o Karan Ram Sinha Aged About 49 Years R/o Village Junvani, Post And Tahsil Narherpur, District Bastar Chhattisgarh. 27 - Ravindra Kumar Pujari S/o Arjun Pujari Aged About 37 Years R/o Village Darapara, Post And Tahsil Bijapur, District Bijapur Chhattisgarh. 3 28 - Maheshwar Nag S/o Mukaram Nag Aged About 37 Years R/o Near Krishan Tent House, Sukma, Post And Tehsil Sukma, District Dantewada Chhattisgarh. 29 - Madkam Kosa S/o Madkam Ganga Aged About 40 Years R/o Village Arlampalli, Post And Tahsil Sukma, District Bastar Chhattisgarh. 30 - Pravir Chandra Negi S/o Kishan Kumar Negi Aged About 36 Years R/o House No. 246. Khaspara Near High School, Post And Tahsil Sukma, District Bastar Chhattisgarh. 31 - Shailendra Kumar Baidh S/o Sadhuram Baidh Aged About 34 Years R/o Village Badedongar, Bazarpara, Post And Tahsil Badedongar, District (Kondagaon Chhattisgarh).
32 - Kailash Kumar Manjhi S/o Nilap Singh Manjhi Aged About 33 Years R/o Nayapara, Post And Tahsil Narayanpur, District Narayanpur Chhattisgarh. 33 - Ravindra Netam S/o Devnath Netam Aged About 37 Years R/o Village - Juganikalar, House No. 42, School Para, Gumdi, Post And Tahsil Kondagaon, District Kondagaon Chhattisgarh. 34 - Shiv Kumar Poyam S/o Chamru Ram Poyam Aged About 36 Years R/o Ward No. 16, Tahsil Kondagaon, District Kondagaon Chhattisgarh. 35 - Harish Chandra Rana S/o Amar Singh Rana Aged About 37 Years R/o Village Gudari Para Road, Post And Tahsil Bahigaon, Keskal, District Kondagaon Chhattisgarh. 36 - Pawan Kumar Netam S/o Charan Singh Netam Aged About 32 Years R/o Village Aamgaon, Post And Tahsil Kondagaon, District Kondagaon. 37 - Bharat Bhushan Singh S/o Komal Singh Aged About 40 Years R/o Village Pharasgaon, Post And Tahsil Kondagaon, District Kondagaon Chhattisgarh. 38 - Laleshwari Sahu D/o Mohit Kumar Sahu Aged About 33 Years R/o Village Haradula, House No. 146, Post And Tahsil Haradula, District Kanker Chhattisgarh. 39 - Darasvatti Bhuarya S/o Harishchandra Bhuarya Aged About 33 Years R/o Village Bargaon, Post And Tahsil Hatkondal, District Kanker Chhattisgarh. 40 - Prakash Singh Tirasuniya S/o Kamal Singh Tirasuniya Aged About 35 Years R/o Village Bansla, Post And Tahsil Bansla, District Kanker Chhattisgarh. 41 - Tukeshvar Kumar Bhuarya S/o Bisram Bhuarya Aged About 39 Years R/o Village Karmoti, Post And Tahsil Bhanupratappur, District Kanker Chhattisgarh. 4 42 - Bala Ram Jain S/o Vishu Ram Jain Aged About 50 Years R/o Ward No. 15, Gurunanak Ward, Tahsil Charama, District Kanker Chhattisgarh. 43 - Neeraj Yadav S/o Chandrashekar Yadav Aged About 43 Years R/o Village Girhola, Post And Tahsil Kanker, District Kanker Chhattisgarh. 44 - Mahattam Kumar Juri S/o Moti Lal Juri Aged About 45 Years R/o Ward No. 10, Post And Tahsil Charama, District Kanker Chhattisgarh. 45 - Jaiprakash Jain S/o Rameshwar Jain Aged About 33 Years R/o Ward No. 08, Post And Tahsil Korar, District Kanker Chhattisgarh.
46 - Mahendra Kumar Jain S/o Dilip Kumar Jain Aged About 46 Years R/o Village Singerbhatt, Post And Tahsil Kanker, District Kanker Chhattisgarh. 47 - Shiv Kumar Ratre S/o Vishwa Mohan Ratre Aged About 38 Years R/o Village Chapora, Ward No. 9, Post And Tahsil Raipur, District Raipur Chhattisgarh. 48 - Purushottam Sori S/o Yogendra Sori Aged About 34 Years R/o Village Burjabahar, District Gariyaband Chhattisgarh. 49 - Bhawendra Kumar Sahu S/o Lomas Ram Sahu Aged About 37 Years R/o Village Lofandi, Post Baltukri, District Gariyaband Chhattisgarh. 50 - Komal Ram S/o Gangu Ram Aged About 36 Years R/o Ward No. 3, Tahsil Sahaspur, District Raipur Chhattisgarh. 51 - Anand Sagar Bisi S/o Narsingh Bisi Aged About 39 Years R/o Village Sondelela, Post And Tahsil Raigarh, District Raigarh Chhattisgarh. 52 - Harsha Thawait D/o Gauri Shankar Thawait Aged About 35 Years R/o Ward No. 6, Madhuban Modi Para, Tahsil Raighar, District Raighar Chhattisgarh. 53 - Lokesh Kumar Patel S/o Jagdish Prasad Patel Aged About 38 Years R/o Main Market, Katkaliya, District Raighar Chhattisgarh. 54 - Rawel Kumar S/o Jagsu Prasad Aged About 33 Years R/o Ward No. 16, House No. 86, Sulsuli, Tahsil Balrampur, District Balrampur Chhattisgarh. 55 - Preetam Kumar Bhagat S/o Krishan Ram Bhagat Aged About 36 Years R/o Ward No. 11, Kusmi, District Balrampur Chhattisgarh. 56 - Anup Kumar Toppo S/o Ramesh Ram Aged About 35 Years R/o Village Kamalpur, Tahsil Balrampur, District Balrampur Chhattisgarh. 57 - Mithlesh Netam S/o Rambharos Singh Aged About 36 Years R/o House No. 30 Atal Chock, Village Parsagudi, District Balrampur Chhattisgarh. 58 - Dushyant Bhagat S/o Mangal Sai Aged About 33 Years R/o Ward No. 6, Banglapara, Harri, District Balrampur Chhattisgarh. 5 59 - Shailesh Kumar Mehta S/o Raghubeer Prasad Mehta Aged About 39 Years R/o Village Darridih, Post Balrampur District Balrampur Chhattisgarh. 60 - Sandeep Kumar Bhagat S/o Lalsai Bhagat Aged About 33 Years R/o House No. 26, Main Road, Rajpur, Tahsil Rajpur, District Balrampur Chhattisgarh.
61 - Sanjay Kumar Soni S/o Neelam Prasad Aged About 32 Years R/o Bangla Road, Sanaval, District Balrampur Chhattisgarh. 62 - Vimlesh Singh S/o Vijay Singh Aged About 45 Years R/o Village Aragahi Khas, Tahsil Balrampur District Balrampur Chhattisgarh. --- Petitioners versus 1 - The State Of Chhattisgarh Through The Secretary, Department Of Revenue And Disaster And Management, Mahanadi Bhawan, Naya Raipur, District Raipur Chhattisgarh. 2 - Commissioner Land Records State Of Chhattisgarh, Indravati Bhawan, 1st Floor Block - 2, Nava Raipur, Atal Nagar, District Raipur Chhattisgarh. 3 - Director Land Records, State Of Chhattisgarh, Indravati Bhawan, Nava Raipur, Atal Nagar, District Raipur Chhattisgarh. 4 - High Level Investigation Committee Through Shri K.D. Kunjam, Special Secretary, Food Civil Supplies And Consumer Protection Department, Mantralay, Mahanadi Bhavan, Naya Raipur, Atal Nagar, District Raipur Chhattisgarh.
--- Respondents WPS No. 1739 of 2025 1 - Harish Kumar S/o Mansai Ram Aged About 42 Years R/o Village Katanga Police Station Duldula Charaidand Duldula Jashpur Chhattisgarh 2 - Shivkant Soni S/o Shiv Kumar Soni Aged About 36 Years R/o Karbala Road Near Filter Plant Jashpur Nagar, District Jashpur Chhattisgarh 3 - Shyamu Singh S/o Nandlal Singh Aged About 34 Years R/o House No. 32 Ghulmul District Jashpur Chhattisgarh 4 - Anwar Vipin Toppo S/o Raphail Toppo Aged About 44 Years R/o Amba Toil, Duldula District Jashpur Chhattisgarh 5 - Mumtaz Tirky D/o Jaiman Tirky Aged About 32 Years R/o House No. 13 9, Bagicha Kilkila Nawapara Dhodharamba Post Office Marol District Jashpur Chhattisgarh 6 - Krishna Kant Painkra S/o C/o Budhnath Singh Painkra Aged About 36 Years R/o Ward No. 11 Mayurnacha Junapara Pathalgaon, Mayurnacha Jashpur Chhattisgarh 6 7 - Sudhir Tirky S/o Suleman Tirky Aged About 42 Years R/o Jamuna, Jashpur Tapkara District Jashpur Chhattisgarh Pin Code 496227 8 - Pradeep Kumar Soni S/o Ramnath Soni Aged About 45 Years R/o House No. 87, Ward No. 3 Baniya Toil Jashpur Post Office Jashpurnagar District Jashpur Chhattisgarh 9 - Manoj Kumar Nishad S/o Sewak Ran Nishad Aged About 45 Years R/o House No 39/01 Bhejaridand, Ankira, Jashpur Chhattisgarh Pin 496245 10 - Hitendranath Paikra S/o Shivnarayan Sai Paikra Aged About 36 Years R/o Bajarpara Pandripani Kunkuri Jashpur District Jashpur Chhattisgarh ---Petitioners Versus 1 - State Of Chhattisgarh Through The Secretary Department Of Revenue And Disaster Management Mahanadi Bhawan Naya Raipur 2 - Commissioner Land Records State Of Chhattisgarh, Indravati Bhawan, 1st Floor, Block-2 Naya Raipur Atal Nagar District Raipur Chhattisgarh 3 - Director Of Land Records State Of Chhattisgarh Indravati Bhawan Naya Raipur Atal Nagar District Raipur Chhattisgarh 4 - High Level Investigation Committee Through Shri K.D. Kunjam Special Secretary, Food Civil Supplies And Consumer Protection Department Ministry Mahanadi Bhawan Naya Raipur Atal Nagar District Raipur Chhattisgarh --- Respondents WPS No. 1727 of 2025 1 - Pradeep Chandrakar S/o Surendra Kumar Chandrakar Aged About 34 Years R/o H.No. 7, Ward No. 8, Behind Sai Mandir Rajnandgaon Raod, B.T.C. Kawardha And Post Office Kawardha, District- Kabirdham (C.G.) 2 - Ajay Kumar Sonwani S/o Dharam Parsad Sonwani Aged About 34 Years R/o H.No. 49/1, Ward No. 5, Kuwa Malgi, Kolhegaon, Kawardha, District- Kabirdham (C.G.) 3 - Amit Kumar Gendle S/o Sunil Kumar Gendle Aged About 35 Years R/o H.No. 8,
Village Kanjheti Satnamipara, Tahsil Pandariya, Kawardha, District- Kabirdham (C.G.) 4 - Nem Singh Jaiswal S/o Samaru Jaiswal Aged About 35 Years R/o Ward No. 2 Nayapara Kosmanda, District- Kabeerdham (C.G.) 5 - Satanand Kumar Chandrakar S/o Dilip Chandrakar Aged About 35 Years R/o H.No. 120 Ward No. 1 Rengabord Mahali, District- Kawardha (C.G.) 7 6 - Rajaram Pusam S/o Dhanup Pusham Aged About 33 Years R/o 85 Gaon - Chhuhi, Post Baijalpur, Teh. Bodla, District- Kabirdham (C.G.) 7 - Radhika Jhariya D/o Ramesh Jhariya Aged About 32 Years R/o 14 Taro, Kawardha, Bodla, District- Kabeerdham (C.G.) 8 - Abilash Verma S/o Setram Verma Aged About 35 Years R/o 66-A Raheja Greens Sankri, Pirda-2, (Pirda) District- Raipur (C.G.) 9 - Shrawan Kumar Gupta S/o Shriram Gupta Aged About 35 Years R/o Ward No. 12 Bhairamgarh, Bijapur, District- Bijapur (C.G.)
---Petitioners Versus 1 - State Of Chhattisgarh Through The Secretary Department Of Revenue And Disaster Management Mahanadi Bhawan Naya Raipur 2 - Commissioner Land Records State Of Chhattisgarh Indravati Bhawan, 1st Floor, Block- 2 Naya Raipur Atal Nagar, District- Raipur C.G. 3 - Director Of Land Records State Of Chhattisgarh Indravati Bhawan Naya Raipur Atal Nagar District- Raipur C.G. 4 - High Level Investigation Committee Through Shri K.D. Kunjam Special Secretary, Food Civil Supplies And Consumer Protection Department Ministry Mahanadi Bhawan, Naya Raipur Atal Nagar, District- Raipur C.G.
--- Respondents WPS No. 1206 of 2025 1 - Dhananjay Singh S/o Amarjeet Singh Aged About 30 Years R/o Ward No. 13, Vivekanand Colony, P.S. - Manendragarh, District - Manendragarh Chirmiri Bharatpur Chhattisgarh 2 - Manjeet Kumar Yadav S/o Ram Nagina Yadav Aged About 32 Years R/o Police Line, P.S. - Jainagar, District - Surajpur Chhattisgarh 3 - Amit Sinha S/o Abhay Prakash Sinha Aged About 37 Years R/o Village - Govindpur, Turraline, P.S. - Govindpur, District - Surajpur Chhattisgarh 4 - Md.
Razwan Ali S/o Md Asharaf Ali Aged About 37 Years R/o Ward No. 14, Ketka Rode, P.S. - Surajpur, District - Surajpur Chhattisgarh 5 - Prakash Kumar Singh S/o Jai Bahadur Singh Aged About 30 Years R/o In Front Of Rest House, Songara, P.S. - Surajpur, District - Surajpur Chhattisgarh 6 - Sarita Keshri W/o Pradeep Jaiswal Aged About 35 Years R/o Village - Brindawan, House No. 37, P.S. - Prem Nagar, Bakalo, District - Surajpur Chhattisgarh 8 7 - Renuka Kashyap W/o Ramshankar Kashyap Aged About 36 Years R/o Village - Pratapur, P.S. - Surajpur, District - Surajpur Chhattisgarh 8 - Pooja Mishra W/o Vijay Kumar Mishra Aged About 36 Years R/o Infront Of Carmel Convent School, Satpata, Post - Bishrampur, P.S. - Bishrampur, District - Surajpur Chhattisgarh 9 - Riya Das D/o Govind Das Aged About 32 Years R/o Ward No. 15, Pendra Dafai, P.S. - Manendragarh, District - Manendragarh Chirmiri Bharatpur Chhattisgarh 10 - Arun Kumar Jaiswal S/o Mooldhar Prasad Jaiswal Aged About 42 Years R/o Bhaiyathan Road, Mishra Gali, Gopalpur, P.S. - Gopalpur, District - Surajpur Chhattisgarh 11 - Teekan Kumar Rajwade S/o Ishwar Prasad Rajwade Aged About 43 Years R/o Village - N.H. 173 Limbadand, Dwarikanagar, Latori, District - Surajpur Chhattisgarh 12 - Samai Pratap Singh S/o Chandrika Prasad Singh Aged About 36 Years R/o Village - Khadgava, Post And Tehsil - Surajpur, District - Surajpur Chhattisgarh 13 - Vinod Singh S/o Ramnath Singh Aged About 37 Years R/o Village - Na Damali, Bandhanpara, Post And Tehsil - Surajpur, District - Surajpur Chhattisgarh 14 - Ashish Kumar Sahu S/o Late Ramvilas Sahu Aged About 41 Years R/o Ward No. 14, Badkapara, P.S. - Surajpur, District - Surajpur Chhattisgarh 15 - Nirmal Kumar Tiwari S/o Ujjain Tiwari Aged About 35 Years R/o Village - Khorma, Post - Pratappur, District - Surajpur Chhattisgarh 16 - Manish Kumar Shrivastav S/o Sunil Shrivastav Aged About 35 Years R/o Village - Ramnanagr, P.S. - Ramnagar, District - Surajpur Chhattisgarh 17 - Saurabh Goswami S/o R.P. Goswami Aged About 35 Years R/o Village - Badsara, Bhaiyathan, District - Surajpur Chhattisgarh 18 - Rajeev Lochan Singh S/o Amarendra Singh Aged About 43 Years R/o Ward No. 10, Premnagar, P.S. - Premnagar, District - Surajpur Chhattisgarh 19 - Sunil Kumar Paikra S/o Rajnath Singh Aged About 45 Years R/o Village - Koteya, Post And Tehsil - Surajpur, District - Surajpur Chhattisgarh 20 -
Amitesh Swarnkar S/o Pradeep Soni Aged About 34 Years R/o Mahavir Ward, D.C. Road, Ambikapur, District Surguja Chhattisgarh 21 - Pratap Ram Painkra S/o Shiya Ram Aged About 39 Years R/o Ward No. 7, Samblpur, Tahsil And Post - Latori, District - Surajpur Chhattisgarh 22 - Raja Ram Ravi S/o Bihari Ram Aged About 25 Years R/o Ward No. 5, Keshavnagar, District - Surajpur Chhattisgarh 9 23 - Divakar Singh S/o Harilal Singh Aged About 34 Years R/o Village - Chharcha, Post And Tahsil - Baikunthpur, District - Baikunthpur-Koriya Chhattisgarh 24 - Ramchandra S/o Raghunath Aged About 48 Years R/o Ward No. 19, Jampara, P.S. - Baikunthpur, District Koriya Chhattisgarh 25 - Ramdev Ram S/o Ashok Kumar Aged About 44 Years R/o Ward No. 11, Kachari Para, P.S. - Baikunthpur, District Koriya Chhattisgarh 26 - Asha Bhagat D/o Kamal Sai Bhagat Aged About 32 Years R/o Village - Bhandi, Post And Tahsil - Baikunthpur, District Koriya Chhattisgarh 27 - Anjali Gupta D/o Pradeep Gupta Aged About 32 Years R/o Ward No. 14, Bajarpara, P.S. - Baikuntpur, District Koriya Chhattisgarh 28 - Prakash Sahu S/o Sobhnath Sahu Aged About 29 Years R/o Ward No. 4, Jobapara, Ohari, Post - Barbaspur, District Koriya Chhattisgarh 29 - Surya Kant Nishad S/o Bisauha Ram Nishad Aged About 45 Years R/o Village - Amti, Nikum, Post And Tahsil - Durg, District Durg Chhattisgarh 30 - Bhaskar Sahu S/o Mahendra Kumar Sahu Aged About 34 Years R/o Ramnagar Ward 13, Bhilai, District - Durg Chhattisgarh 31 - Shilpa Yadav D/o Chandra Kumar Yadav Aged About 33 Years R/o Lig Ground, House No. 280, Padmanabhapur, District - Durg Chhattisgarh 32 - Sweta Jendre W/o Chandra Bhan Barre Aged About 34 Years R/o Ward No. 25, Shanta Kunj, Post And Tahsil - Durg, District - Durg Chhattisgarh 33 - Kanchan Dadsena D/o Loknath Dadsena Aged About 38 Years R/o Village - Rajasewaiya, Post And Tahsil - Pithora, District
Mahasamund Chhattisgarh 34 - Rakesh Kumar Chandrakar S/o Vishnu Prasad Chandrakar Aged About 34 Years R/o Village - Khopli, Bastipara, Post And Tahsil - Bagbahra, District Mahasamund Chhattisgarh 35 - Rakesh Kumar Tamrakar S/o Ram Kumar Tamrakar Aged About 38 Years R/o Ward No. 11, Post And Tahsil - Lavan, District - Baloda Bazar- Bhatapara Chhattisgarh 36 - Vinita D/o Shyamji Lal Aged About 35 Years R/o Village - Khokli, Post And Tahsil - Jaraud, District Baloda Bazar-Bhatapara Chhattisgarh 37 - Rishikesh Mishra S/o Narendra Mohan Mishra Aged About 43 Years R/o Mahamaya Chock, Post And Tahsil - Lavan, District - Baloda Bazar - Bhatapara Chhattisgarh 38 - Satyawan Pathak S/o Rameshwar Prasad Pathak Aged About 42 Years R/o Village Kasdol, District - Baloda Bazar - Bhatapara Chhattisgarh 10 39 - Yogendra Kumar Sharma S/o Mani Prasad Sharma Aged About 44 Years R/o Village - Parsabadher, Post And Tahsil - Baloda Bazar - Bhatapara Chhattisgarh 40 - Jitendra Kumar Dhruw S/o Umeram Dhruw Aged About 39 Years R/o Village - Amalidiha, Post And Thasil - Narayanpur, District - Bemetara Chhattisgarh 41 - Bhuwan Singh Dhruw S/o Ramphal Dhruw Aged About 46 Years R/o Village - Khapri, Post And Tahsil - Bilaspur, District Bilaspur Chhattisgarh 42 - Manish Kumar Varma S/o Uittra Kumar Varma Aged About 33 Years R/o Jabdapara, Post And Tahsil - Bilaspur, District - Bilaspur Chhattisgarh 43 - Vibhav Singh S/o M.K. Singh Aged About 50 Years Village - Rajkishor Nagar, Post And Tahsil - Bilaspur, District - Bilaspur Chhattisgarh 44 - Bindu Sanadya D/o Ragu Prasad Sanadya Aged About 35 Years R/o Village Mendra, Post And Tahsil - Chakarbhata, District - Bilaspur Chhattisgarh 45 - Ajit Kumar Nirmalkar S/o Ram Kumar Nirmalkar Aged About 35 Years R/o Village - Parsada Bharnai, Tahsil - Ganiyari, District - Bilaspur Chhattisgarh 46 - Rahul Kumar Sahu S/o Gorelal Sahu Aged About 34 Years R/o Sakri, Post And Tahsil - Sakri,
District - Bilaspur Chhattisgarh 47 - Sunil Kumar Karn S/o Bachchu Lal Karn Aged About 38 Years R/o Ward No. 21, House No. 21, Tahsil - Rajnandgaon, District - Rajnandgaon Chhattisgarh 48 - Shubham Sharma S/o Sunil Kumar Sharma Aged About 32 Years R/o Ward No. 8, Amapara, Post And Tahsil - Ambagarh-Chouki, District Mohla Manpur Ambagarh Chouki Chhattisgarh 49 - Pradeep Dewangan S/o Charan Dewangan Aged About 36 Years R/o Ward No. 19, Gali No. 3, Tahsil - Rajnandgaon, District - Rajnandgaon Chhattisgarh 50 - Bhupendra Kumar Kande S/o Gyan Das Khande Aged About 42 Years R/o Ward No. 12, Gautam Nagar, Tahsil - Rajnandgaon Chhattisgarh 51 - Vibha Mishra Tiwari W/o Alok Tiwari Aged About 41 Years R/o New Khandelwal Colony, Mamta Nagar, District - Rajnandgaon Chhattisgarh 52 - Shweta Sharma D/o Suresh Kumar Sharma Aged About 38 Years R/o Ward No. 39, Mahesh Nagar, Tahsil - Rajnandgaon, District - Rajnandgaon Chhattisgarh 53 - Safeer Ahmad Khan S/o Habibulla Khan Aged About 45 Years R/o Ward No. 17, Post And Tahsil - Rajnandgaon, District Rajnandgaon Chhattisgarh 11 54 - Mamta Dubey D/o Suresh Kumar Dubey Aged About 34 Years R/o Ward No. 5, Post And Tahsil - Kawardha, District Kawardha Chhattisgarh 55 - Santram Gote S/o Ramsai Gote Aged About 46 Years R/o Ward No. 5, Telitola, District Rajnandgaon Chhattisgarh 56 - Shakuntala Vaishnav W/o Devesh Vaishnav Aged About 34 Years R/o Gali No. 2, Ward No. 11, Shantinagar, District - Rajnandgaon Chhattisgarh 57 - Vikesh Kumar Soni S/o Ramesh Chandra Soni Aged About 47 Years R/o House No. 93/2, Ward No. 22, Devan Para, Tahsil - Rajnandgaon Chhattisgarh 58 - Anil Kumar Sahu S/o Tameshwar Prasad Sahu Aged About 34 Years R/o Ward No. 06, Banhardi, District - Rajnadgaon Chhattisgarh 59 - Ray Singh S/o Prem Singh Aged About 35 Years R/o Ward No. 10, Fulkodo, Bharritola, District - Rajnandgaon Chhattisgarh 60 - Suman Chandravanshi W/o Human
Lal Kanwar Aged About 32 Years R/o Ward No. 14, Manikpur, Post - Ramatola, District - Rajnandgaon Chhattisgarh 61 - Jineshwari Sahu W/o Narendra Kumar Sahu Aged About 46 Years R/o Ward No. 4, Matiyaroad, Dongargao, District - Rajnandgaon Chhattisgarh 62 - Vikas Kumar Vasnik S/o Vijay Vasnik Aged About 32 Years R/o House No. 62, Ward No. 6, Ambagarh Chouki, District - Mohla Manpur Ambagarh Chouki Chhattisgarh 63 - Ajay Bara S/o Dharamsai Bara Aged About 33 Years R/o Village - Tihpatra, District Surguja Chhattisgarh 64 - Kanni Lal Beck S/o Jharoo Ram Beck Aged About 51 Years R/o House No. 102/3, Gangapur Khurd, District - Ambikapur-Surguja Chhattisgarh 65 - Manoj Kumar S/o Ramdayal Singh Aged About 40 Years R/o Junapara, Krishnanagar, District - Surguja Chhattisgarh 66 - Ankita Tirkey D/o Rajrup Tirkey Aged About 33 Years R/o Ghoom Para, Ambikapur, District - Surguja Chhattisgarh 67 - Santosh Kumar Ekka S/o Jeetu Markush Ekka Aged About 44 Years House No. 22, Mainpat, District - Surguja Chhattisgarh 68 - Anil Kumar Xalxo S/o Benjamin Xalxo Aged About 37 Years R/o Gutara Para, Losanga, District Surguja Chhattisgarh 69 - Jeet Lal Singh S/o Bishun Ram Aged About 42 Years R/o Village - Bataikela, District - Surguja Chhattisgarh 12 70 - Surya Prakash Joshi S/o Bhagirathi Joshi Aged About 42 Years R/o Ward No. 46, House No. 17, Bilaspur Road Laxmipur, District - Surguja Chhattisgarh 71 - Shripal Beck S/o Dasai Ram Beck Aged About 37 Years R/o Village - Parsapali, District - Surguja Chhattisgarh 72 - Anita Kujur D/o Shobha Kujur Aged About 41 Years R/o House No. 214, School Para, Batwahi, District - Surguja Chhattisgarh ---Petitioners Versus 1 - The State Of Chhattisgarh Through The Secretary, Department Of Revenue And Disaster Management, Mahanadi Bhawan, Naya Raipur, District Raipur Chhattisgarh 2 - Commissioner Land Records State Of Chhattisgarh, Indravati Bahwan, 1st Floor Block-2 Nava Raipur, Atal Nagar, District - Raipur Chhattisgarh
3 - Director, Land Records State Of Chhattisgarh, Indravati Bahwan, Nava Raipur, Atal Nagar, District - Raipur Chhattisgarh 4 - Shri K.D. Kunjam Chairman, High Level Investigation Team, Also Special Secretory, Food Civil Supplies And Consumer Protection Department, Mantralay, Mahanadi Bahavan, Nava Raipur, Atal Nagar, District - Raipur Chhattisgarh --- Respondents For Petitioners : Mr. Sunil Tripathi, Mr. Aman Keharwani, Mr. Shalvik Tiwari, Mr. Qamrul Aziz and Mr. Rohitashav Singh, Advocates For State : Mr. Suyash Dhar, Dy. Government Advocate and Mr. Sabyasachi Choubey, Panel Lawyer For Intervenor : Ms. Palak Dwivedi, Ms. Neha Khandekar & Mr. Shubham Dwivedi, Advocates Hon'ble Shri Narendra Kumar Vyas, J.
CAV ORDER
1. Since an identical issue and common question of facts are involved in these writ petitions, they are heard analogously and are being decided by this common order. 2. In pursuance of direction given by this Court, Mr. K.D. Kunjam, Special Secretary Food, Dr. Fariya Alam Siddiqui, Dy. Secretary School
13 Education, Ms. Anshika Rishi Pandey, Dy. Secretary GAD, Mr. Rakesh Sahu, Dy. Secretary Skill Development, Mr. Ajay Tripathi, Dy. Secretary GAD members of the High-Level Investigation Committee and Mr. Harshwardhan Singh, Revenue Department appeared before this Court. 3. The petitioners have filed the present bunch of writ petitions seeking a direction to the respondent authorities to issue call letters/notices for initiation of Revenue Inspector Training pursuant to the departmental examination conducted vide memo dated 25.09.2023 and the selection list published on 23.10.2024. 4. The brief facts, as projected by the petitioners are that they are presently working as Patwaris at different places within the State of Chhattisgarh and each of them possesses more than five years’ experience on the said post. Respondent No. 3, vide memo dated 25.09.2023, invited applications for conducting a departmental examination for promotion from the post of Patwari to that of Revenue Inspector.
As per the said memo, all Patwaris having more than five years’ experience were eligible to submit their applications in the prescribed format to their respective Tehsildars on or before
30.10.2023. In response thereto, approximately 2600 candidates submitted their applications. The departmental examination was conducted on 07.01.2024 and the result was thereafter uploaded on 29.02.2024, whereby 216 candidates were declared successful. Meanwhile, respondent No. 1, vide order dated 23.08.2024, constituted a High-Level Investigation Committee comprising five members as there was complaint regarding malpractice adopted in
14 conducting examination, declaration of result. The Committee was required to submit its report within 15 days from the date of its constitution. Subsequently, respondent No. 3, on 05.09.2024, issued a communication to all the Collectors for verification of documents of the eligible Patwaris who had qualified the written examination. Upon completion of the document verification process, respondent No. 2 published the final list of eligible candidates for undergoing Revenue Inspector Training, wherein the names of the present petitioners were duly included. The grievance of the petitioners is that despite publication of the final selection list, the respondent authorities have, till date, not issued any call letters for commencement of Revenue Inspector Training, whereas as per Rule 10 of the Bhu Abhilekh Niyamawali, the training programme of all Revenue Inspectors is required to commence on 1st October of every year. 5. It has been further contended that earlier, some similarly situated selected candidates had approached this Court by filing WPS No. 7889/2024 (Girdhar Gopal Rathor and Others vs. State of Chhattisgarh), which was disposed of vide order dated 14.01.2025 directing the respondent authorities to take a decision regarding commencement of training within a short time. However, despite the said direction, no decision has been taken by the respondent authorities till date though the petitioners have repeatedly approached the respondent authorities seeking initiation of their Revenue Inspector Training, but the matter is being unnecessarily delayed on the sole ground that the High-Level Investigation Committee has not yet submitted its report.
Left with no other efficacious remedy, the petitioners have filed the present writ petitions seeking appropriate
15 directions to the respondents for initiation of Revenue Inspector Training and a direction be also issued to the respondent No. 4 to submit its report. 6. It has been further contended that the allegations of adoption of unfair means were levelled against seven Patwaris, out of whom four did not qualify the departmental examination and only three were declared successful, as such, it cannot be presumed that there was leakage of question paper. Therefore, the allegation of leakage of question paper is wholly baseless and speculative. It has further been stated that the column relating to mobile numbers was allegedly wrongly mentioned in the OMR sheets; however, the same was never raised or objected to either before or during the conduct of the examination by any candidate. Similarly, the mere fact that some candidates who are related to each other were allotted nearby roll numbers does not invalidate the examination process, particularly in the absence of any evidence showing manipulation or prejudice. It is further contended that the petitioners who are successful candidates are sufferers without their fault, as such, the petitioners cannot be deprived from their rightful claim for undergoing further training for promotion to the post of Revenue Inspector. Even the respondents have not made out a case for mass cancellation of examination as the alleged irregularities do not go to the root cause of the examination process which may vitiate the entire examination process. Thus, the petitioners would contend that a direction be kindly issued to the respondents to initiate the process for sending the candidates for training in a phased manner immediately. 16
7. The respondent/State has filed its return wherein it has admitted that respondent No. 3, Director, Land Records, State of Chhattisgarh, vide letter dated 25.09.2023, invited applications for conducting the departmental examination for promotion from the post of Patwari to that of Revenue Inspector.
The said departmental examination was conducted on 07.01.2024 and the result thereof was uploaded on 29.02.2024, whereby 216 candidates were declared successful (Annexure P/2). 8. It has been further contended by the State in its return that subsequently, complaints were made by five Patwaris to the State Head of the Revenue Patwari Association, Chhattisgarh, alleging serious irregularities in the conduct of the said departmental examination. It was alleged that the question paper had been leaked to certain favoured Patwaris and specific allegations were levelled against six Patwaris and one officer of the rank of Assistant Statistical Officer posted in the office of the Regional Deputy Commissioner. The said complaint was forwarded by the Patwari Association to the Hon’ble Revenue Minister vide letter dated 29.01.2024. Considering the seriousness of the allegations, a five-member High Level Enquiry Committee was constituted vide order dated 23.08.2024 by the Under Secretary, Revenue & Disaster Management Department, Raipur, with the approval of the Hon’ble Chief Minister. The Committee was headed by the Special Secretary, Food, Civil Supplies and Consumer Protection Department. Since the enquiry into the allegations of malpractice while conducting departmental examination was at a nascent stage, the process of sending the selected Patwaris for training to the post of Revenue Inspector was kept in abeyance. In the
17 meantime, the Director, Land Records, called for information regarding the experience of the selected candidates from the concerned Collectors in the prescribed format and, vide letter dated 23.10.2024, an intimation was issued by the Joint Commissioner, Land Records, Naya Raipur, Atal Nagar, District Raipur, regarding verification of the selected Patwaris. The High Level Enquiry Committee submitted its report to the Secretary, Revenue & Disaster Management Department, Raipur, vide letter dated 29.11.2024.
After conducting an extensive enquiry, the Committee found that the complainants had failed to produce any documentary evidence in support of their allegations and has pointed out certain procedural irregularities relating to the conduct of the examination which are as under:- A. That no reservation was provided in the examination though it was conducted for promotion on the post of Revenue Inspector which is in violation of recruitment rules. B. The syllabus of the examination was issued twice in which there is no reference of Bhuiya Software despite these questions were put on Bhuiya Software which is out of syllabus. C. While issuing admission card, specific direction was given that except in the specified place of OMR sheet no marking, roll number, should be mentioned, but in the OMR sheet column for mentioning mobile number has been provided which is personal and it effects secrecy and purity of the examination adversely. D. The committee has also found that 240921 was issued to Harshwardhan Mordhare, he was selected but subsequently, his name was removed from the list and in his place in roll number 241921 of
18 Pawan Kumar Netam was manually added in the selection list which creates doubt by manipulating roll number 241921 as 240921. E. It has also been pointed out that two brothers were allotted roll number 241797 and 241798, with an object of allowing them to seat together at Surguja Centre. Similarly, two brothers have been allotted roll number 241975 and 241976 at District Bastar and one set of brothers were allotted Roll number 241770 and 241771 who belongs to different districts but they are brothers and they have been allotted one district Bemetara. Likewise roll numbers 240779 and 240780 who are from different districts i.e. Bastar and Dhamtari but they have been allotted one district and seriatum in roll number with object of giving undue advantage or favoritism in the examination.
F. The committee has also found that close relatives who are brothers, husband-wife/sister-in-law have been selected which creates doubt over conduction of fair examination. G. The committee has also found that initially the examination was to be conducted on 50 questions and for which time slot was given 90 minutes, but all of a sudden the questions have been doubled and the 100 questions had to be answered in same time of 90 minutes. Similarly, in question paper for last questions, answers were given in next page, which consume extra time, as such in short span of 90 minutes asking the candidates to answer 100 questions create doubt over the manner in which examination was conducted. The committee has also found that some of the candidates have obtained 90 marks which is impossible to dark round over the correct answer, as such, possibility of leaking out of the question paper cannot be ruled out. 19 The committee has also found that earlier in the departmental examination the maximum mark was 80 and cut off mark was 36 whereas in the present examination maximum mark is 90 and cut off is 64 even though 3 questions have been deleted. As such, maximum mark of 90 obtained by the candidates creates doubt over the purity of the examination and has also apprehended that the question papers have been sold, as such it has suggested for obtaining call details of all the selected candidates and officers who have participated or involved in the examination. 9. On the recommendation of the Committee with regard to the allegations, the State Government considering requirement of forensic and police investigation found it appropriate to refer the matter for further enquiry and forwarded matter vide letter dated 16.01.2025 to the Additional Chief Secretary, Department of Home (Police), Mahanadi Bhawan, Naya Raipur, Atal Nagar, District Raipur. Consequently, the matter was handed over to the Economic Offence Wing/Anti Corruption Bureau (EOW/ACB), Chhattisgarh, wherein Preliminary Enquiry No. 01/2025 has been registered against the following officers, namely: Shri Ramesh Kumar Sharma, then Director, Land Records, Chhattisgarh; Ms.
Premlata Padmakar, Joint Commissioner, Office of the Commissioner, Land Records; Shri Pushparaj Pradhan, Commissioner (Statistics), Office of the Commissioner, Land Records; Ms. Neha Bhediya, Deputy Commissioner, Office of the Commissioner, Land Records; Smt. Madhu Harsh, Deputy Commissioner, Office of the Commissioner, Land Records; Shri Herman Toppo, Assistant Commissioner (Statistics), Regional Deputy Commissioner, Land Records, Raipur;
20 Shri Keshav Das Ujjawal, Assistant Commissioner (Statistics), Office of the Commissioner, Land Records, Chhattisgarh; Shri Virendra Jatav, Assistant Statistics Officer, Office of the Commissioner, Land Records; Shri Rajendra Chaudhari, Supervisor, Crop Cutting, Office of the Commissioner, Land Records; Shri Hemant Kaushik, Assistant Statistics Officer, Regional Deputy Commissioner, Land Records, Raipur; and Shri Mukesh Kumar Bajaj, Incharge Officer (Swamitwa Yojna), Office of the Commissioner, Land Records. 10. It has been further stated that the said preliminary enquiry has been registered under the provisions of the Prevention of Corruption Act, 1988, as amended by the Prevention of Corruption (Amendment) Act,
2018. In compliance with the statutory requirement under Section 17(A) of the Act, prior sanction was sought by the Director, EOW/ACB, Chhattisgarh, Raipur, and the same was accorded by the deponent vide letter dated 22.04.2025. Thereafter, considering the gravity of the allegations and the conduct of the officials in relation to the Revenue Inspector Departmental Examination, 2024, the department vide letters dated 02.06.2025 and 06.06.2025 granted sanction under Section 17(A) of the Prevention of Corruption Act, 1988 (as amended in 2018) for conducting preliminary investigation against the aforesaid 11 delinquent officials. It has been averred that only after receipt of the report of the EOW/ACB, the deponent would take a final decision in the matter. The delay occured in conducting the departmental enquiry as well as the investigation by the EOW/ACB has been stated to be bona fide and unintentional, undertaken solely to surface the truth in relation to the alleged irregularities. On these grounds, a prayer has also been made that the delay may kindly be condoned by this Hon’ble
21 Court. 11.
Learned counsel for the petitioners would submit that despite lapse of almost one year, the petitioners have not been sent for training for the post of Revenue Inspector. It is contended that the petitioners have a legitimate expectation of appointment pursuant to their selection, and the prolonged and unexplained delay in commencement of training has caused serious prejudice to them. It is further submitted that on account of such delay, the petitioners are suffering adverse civil consequences, including loss of seniority, stagnation in service, and denial of the appropriate pay scale attached to the post of Revenue Inspector, for no fault attributable to them.
12.
Learned counsel for the petitioners would further submit that the Departmental Examination, 2024 was conducted strictly in accordance with the provisions of the Bhu Abhilekh Nimawali Part–2, Chapter–1 and the Chhattisgarh Bhu Abhilekh Nimawali Class–III Non-Gazetted (Executive and Technical) Service Appointment Rules, 2014. It is submitted that none of the candidates raised any objection with regard to the name or mobile number column in the OMR sheets at any point of time prior to declaration of the result of the Departmental Examination, 2024. Therefore, any subsequent objection on the said issue is clearly an afterthought and cannot be made a ground to doubt the sanctity of the examination. The observation of the Committee that the procedure of randomization was not followed on the premise that 22 candidates sitting near each other were allegedly relatives is wholly misconceived. The notification governing the examination does not stipulate any bar on relatives appearing in the departmental
22 examination. Moreover, the High-Level Committee neither conducted any enquiry nor verified from the candidates as to whether they were in fact related to each other. Instead, the Committee merely reproduced the allegations contained in the complaint letter without any independent verification, thereby acting in breach of the principles of natural justice.
13. It is humbly submitted that even as per the findings recorded by the Committee, there exists no substantive or cogent ground warranting cancellation of the entire examination or withholding of training of the selected candidates. The Committee itself has opined that at best there were minor procedural irregularities, which by settled legal principles cannot invalidate the entire promotional examination process. Learned counsel would further submit that the Patwari Promotional Examination was earlier challenged before the Hon’ble Division Bench in WP (PIL) No. 32/2024, which stood dismissed vide
order dated 01.05.2024. The said dismissal further fortifies the validity and legality of the departmental examination process. Therefore, would pray for allowing the writ petitions. To substantiate their submission they would refer to the case of the Hon'ble Supreme Court in case of Anupal Singh and others Vs State of U.P. 2020 (2) SCC 173, Shivanandan C.T. Vs High Court of Kerala, 2024 (3) SCC 799, Sachin Kumar and other Vs. Delhi Subordinate Service Selection Board Reported in 2021 (4) SCC 631 and Union of India and Others Vs Rajesh P.u. Puthuvalnikathu Another reported in 2003 (7) SCC 285. 23
14. Learned State counsel would submit that the present writ petitions have been filed seeking issuance of a writ of mandamus to compel the State authorities to issue call letters for training. It is contended that no legitimate expectation can arise out of a tainted selection process. It is further submitted that although the grievance of the petitioners may deserve sympathy, the relief sought cannot be granted at this stage, as the entire selection process stands clouded by serious allegations of irregularities, including question paper leakage and favoritism. The said allegations are presently under active investigation by competent authorities, including the Economic Offences Wing/Anti-Corruption Bureau. Learned State counsel would argue that permitting the petitioners to undergo training during the pendency of such investigation would compromise the fairness and transparency of enquiry. Learned State counsel places reliance on the judgment of the Hon’ble Supreme Court in State of Assam & Others v. Arabinda Rabha & Others, {2025 INSC 334} , wherein it has been held that the Courts are empowered to uphold cancellation of a recruitment select list where serious irregularities and anomalies in the selection process are detected. On these grounds, they prayed for dismissal of writ petitions. 15. I have learned counsel for the parties and perused the documents placed on record with utmost satisfaction. 16. From the submission made by the parties, the point requires to be determined by this Court is “whether the examination in the year 2023/2024 for promotion from the post of patwari to revenue inspector has been conducted in fair and transparent manner or whether
24 direction is required to be issued by this Court to the State to send the successful patawaris for training of revenue inspector?”
17.
To ascertain this point though there may not be direct material to record such finding, but on the basis of whatever the materials placed by the parties, this Court has to examine the facts and circumstances on the principle of preponderance to reach to its conclusion and for that this Court has to consider the report dated 29.11.2024. 18. From bare perusal of the report dated 29.11.2024 it is quite vivid that in the OMR sheets the mentioning of mobile number has been provided which is clearly not permissible as it effects purity of examination as the identification of the candidate can be very well traced out in it. The mobile number is the best source of contacting the people, identify the person and also for tracing which itself creates doubt over the conduction of examination in a fair manner. Any examination should be conducted in a sacrosanct manner so that its purity and transpency is maintained, even if the mobile number facility provided in the OMR sheets in the year 2018 to 2024, it does not mean that illegality be allowed to perpetuate, the illegalities have to be removed while conducting examination in future also as the examination should always be level played game for all the candidates. There must be no sort of favoritism, nepotism for any candidates. All the candidates should be equally treated. 19. The further reason observed by the committee that number of questions have been doubled to the existing number, as such, the candidates had to solve 100 questions in 90 minutes and some of the candidates have secured 90 marks whereas it is time consuming for
25 darkening the OMR which takes sufficient time and it is practically not possible to attempt 100 questions.
Though on earlier occasion the candidates had to solve 50 questions in 90 minutes, no reason has been placed on record by the State why the officers who are involved in conducting the examination have doubled the question in same time slot deviating from earlier prevailing practice, itself creates doubt. 22 candidates have been allotted roll numbers in seriatum to close relatives who are posted in different districts and no reason has been assigned and it cannot be merely a chance, it has to be done with some planning which cannot be ruled out at this juncture. The law with regard to cancellation of examination is always subject matter of examination before the Constitutional Court and the Constitutional Courts insist for no compromise with sanctity and integrity of examination. The Hon’ble Supreme Court in case of Vanshika Yadav vs. Union of India {(2024) 9 SCC 743] has held that when sanctity of examination is found to be compromised at systemic level and it is not possible to separate tainted candidates from untainted one, then the examination can be cancelled. The Hon’ble Supreme Court has held in paragraph 105 as under :-
105. During the hearing, the petitioners urged that there were systemic flaws in the conduct of the examination and that a more thorough procedure needs to be put in place to ensure that malpractice is avoided. Given the crucial role of the examination in shaping the careers of future medical professionals responsible for public health, any compromise in the merit-based selection process jeopardizes the quality of healthcare as well as the careers of aspirants. The fairness and reliability of the examination system cannot be such that public confidence is lost
20. Thereafter, Hon’ble Supreme Court in case of State of West Bengal vs Baishakhi Bhattacharyya (Chatterjee) and Others {2025 INSC 437} has held in paragraphs 13-19 as under :-
26
13.
The precursor to Inderpreet Singh Kahlon involved raids that led to the recovery of large sums of cash from the house of the Chairman of the Punjab Public Service Commission. The allegations suggested that the Chairman – who served from 1996 to 2002 – had made several appointments between 1998 and 2001 for extraneous considerations, including monetary ones. The affected appellants before this Court, whose services were terminated, comprised four categories of officers selected through four recruitment examinations held between 1997 and 2001. Two FIRs came to be registered against the Chairman and other officers of the Public Service Commission. However, among the selectees, an FIR was filed only against one. In this factual background, Sinha J. drew a distinction between a proven case of mass cheating in a Board Exam and an unproven charge of corruption in the context of appointment of a civil servant. The en masse termination order setting aside several selections spread over 3-4 years was reversed. This was an unprecedented case of mass termination, with a walloping impact and consequences. Applying the threefold factual and legal test, en masse termination was set aside. In this context, it was observed that termination orders should only be issued in cases where it is found to be impossible or highly improbable to separate the tainted cases from the non-tainted ones. 14. In our considered view, the opinion expressed by Dalveer Bhandari J. in Inderpreet Singh Kahlon (supra) regarding the strict compliance with the principles of natural justice is not in line with the ratio of the earlier three Judge Bench decision in Bihar School Examination Board (supra). We would like to observe that the en masse termination in Inderpreet Singh Kahlon (supra) was based on the charge of corruption against the former Chairman, leading to the cancellation of the entire selection process and appointments, even though the charges against him had not yet been proven in a court of law. 15.
Similarly, in another two Judge Bench decision in Joginder Pal v. State of Punjab, this Court observed that every effort should be made to separate tainted from untainted candidates, and if it is found that segregating the tainted from untainted is possible, cancellation of the entire selection process would be incompatible with law. 16. In Chairman, All India Railways Recruitment Board v. K. Shyam Kumar, where the decision of the Railway Recruitment Board to cancel the examination and conduct retest on the ground of malpractices involving mass copying, leakage of question paper and impersonation was struck down by the High Court, this Court – reversing the
judgment of the High Court – upheld the order of the Board to cancel the examination and conduct retest. Considering the material on record, the widespread irregularities and malpractice in the first written test, and the ultimate object of fair selection, this Court upheld the finding of the Board that the test was vitiated due to mass copying, impersonation, and question paper leakage, rather than misconduct by just a few candidates. In the said facts and circumstance, the decision of the Board to cancel the selection and reconduct the examination was held to be reasonable and well-balanced. 17. In State of Tamil Nadu v. A. Kalaimani, there were allegations of large-scale malpractices involving tampering with OMR sheets. After re-evaluation and further scrutiny, the Teachers Recruitment Board
27 found that 196 candidates had been the beneficiaries of fraudulent alteration of marks. This Court referred to the observations in Gohil Vishvaraj Hanubhai v. State of Gujarat to hold that the authority of the State to maintain the purity of the examination process is unquestionable. Gohil Vishvaraj Hanubhai (supra) takes note of the settled dictum that the cancellation of the examination is necessary and required in cases where large-scale malpractices in the course of the conduct of any examination process are alleged. In this context, this Court in A. Kalaimani (supra) held that despite the inconvenience caused to the untainted candidates, a serious doubt regarding the magnitude of manipulation in the examination has to be given due weightage. It was held that the finding of the Board that there were chances of more people being involved in the manipulation of marks was a bona fide decision being taken by the Board to instil confidence in the public regarding the integrity of the selection process. 18. In Vanshika Yadav v. Union of India, this Court observed that a holistic view must be adopted by assessing the extent of unfair means used and whether it is possible to separate the tainted candidates from the untainted ones. The court must ensure that allegations of malpractice are substantiated and that the material on record, including investigative reports, supports this conclusion. There must be at least some evidence for the court to reach such a conclusion. However, the standard of evidence need not be unduly strict. Specifically, the material on record need not point to a single, definitive conclusion that malpractice occurred at a systemic level.
Nevertheless, there must be a real possibility of systemic malaise, as reflected in the material before the court. 19. The following principles emerge from the aforesaid discussion: • When an in-depth factual inquiry reveals systemic irregularities, such as malaise or fraud, that undermine the integrity of the entire selection process, the result should be cancelled in its entirety. However, if and when possible, segregation of tainted and untainted candidates should be done in consonance with fairness and equity. • The decision to cancel the selection en masse must be based on the satisfaction derived from sufficient material collected through a fair and thorough investigation. It is not necessary for the material collected to conclusively prove malpractice beyond a reasonable doubt. The standard of evidence should be reasonable certainty of systemic malaise. The probability test is applicable. • Despite the inconvenience caused to untainted candidates, when broad and deep manipulation in the selection process is proven, due weightage has to be given to maintaining the purity of the selection process. • Individual notice and hearing may not be necessary in all cases for practical reasons when the facts establish that the entire selection process is vitiated with illegalities at a large scale. 21. Again the Hon’ble Supreme Court in Arabinda Rabha(supra) has held as under :-
28
51. Based on what has been discussed in the paragraphs preceding
consideration of the authorities cited by Mr. Goswami, the appellants’ decision in cancelling the entire selection process initiated vide the advertisement dated 23rd July, 2014 relying on the note of the PCCF dated 4th July, 2016, and not part of it, in our considered opinion,does not seem to be either arbitrary or unreasonable or without any sense of proportion. Since the earlier process did border on fraud, inthe light of the reservation policy not being respected and observance of the decisions of this Court (that meritorious reserved category candidates are entitled to be accommodated in the open category) in breach, there was a brazen violation which was sought to be corrected and, if we may say, justifiably so. It has not been proved to our satisfaction that the impugned decision of cancelling the select list is the neat result of an injudicious exercise of discretion and was ill-directed in the guise of achieving the sanctity of the entire selection process.
52. The broad issue and issue (a) (supra) are, thus, answered infavour of the appellants by holding that the impugned decision of cancellation was neither unjustified nor was one which could be upset by applying the doctrines of either Wednesbury unreasonableness or proportionality.
22. The judgments cited by the learned counsel for the petitioners in case of Anupal Singh (supra) do not deal with the present issue raised in this petition as it has been held by the Hon’ble Supreme Court that if the candidate has participated in the selection process he is estopped from challenging the selection process on the principle of estoppel, acquiescence, waiver. In case of Shivnandan C.T. (supra) the issue relates to legitimate expectation but facts and circumstances of the present case itself makes the selection process as doubtful, therefore, the theory of legitimate expectation is not applicable to the present
facts. As the judgments cited by the learned counsel for the petitioners are distinguishable on the facts, the same are not applicable in the present facts.
23. From the facts of the case it is quite vivid that the selection process itself is tainted with malpractice, there is a sign of favourtism, nepotism which vitiate the entire examination itself. Therefore, it is held that the examination has not been conducted in a transparent and fair manner,
29 therefore, no direction can be issued to the respondents to send the petitioners for training for promotional post of Revenue Inspector. Accordingly, the point to be determined by this Court is answered against the petitioners.
24. Before parting with this case, it is made clear that nothing in this
judgment shall be construed as finding of fact in relation to criminal proceeding arising from the present incident of malpractice in conducting the examination and the criminal court will decide the case on the basis of materials placed before it in accordance with law. It is also directed that the respondent State is at liberty to conduct fresh examination for promotion from the post of Patwari to revenue inspector in a fair and transparent manner preserving the sanctity and integrity of the examination.
25. With the aforesaid observation and direction, the bunch of writ petitions stands dismissed.
Sd/- (Narendra Kumar Vyas)
Judge Deshmukh KISHORE KUMAR DESHMUKH Digitally signed by KISHORE KUMAR DESHMUKH Date: 2026.01.02 13:35:31 +0530