[2026:RJ-JP:21963] HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR S.B. Criminal Miscellaneous Bail Application No. 5690/2026 Jogendra Singh S/o Shri Omprakash, Aged About 55 Years, R/o Chidi, Police Station Lakhan Majra, District Rohtak, At Present 113-B/29, Ram Gopal Colony, Police Station Urban State, District Rohtak, Haryana. (Presently Accused Petitioner Is Confined In Central Jail, Jaipur). ----Petitioner Versus State Of Rajasthan, Through P.P. ----Respondent Connected With S.B. Criminal Miscellaneous Bail Application No. 5691/2026 Sangeeta Kadwasara Alias Bhoomi D/o Shri Dharamveer Singh, Aged About 51 Years, R/o Natiol Choti, Police Station Hameerwaas, District Churu Presently D-9, Rupali Enclave, Karala, Police Station Kanjhawala, Delhi. (Presently Accused Petitioner Is Confined In Mahila Jail, Jaipur). ----Petitioner Versus State Of Rajasthan, Through P.P. ----Respondent For Petitioner(s) : Mr. Swadeep Singh Hora For Respondent(s) : Mr. Shree Ram Dhakar, PP Mr. Devendra Kumar, CI SOG Jaipur HON'BLE MR. JUSTICE PRAVEER BHATNAGAR Order Date of conclusion of arguments:- 13.05.2026 Date on which the judgment was Reserved :- 13.05.2026 Whether the full judgment or only the operative part is pronounced:- Full Judgment [2026:RJ-JP:21963] (2 of 14) [CRLMB-5690/2026] Date of pronouncement:- 25.05.2026 1. These bail applications under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 have been filed on behalf of the accused-petitioners in connection with FIR No.12/2026 dated 20.02.2026, registered at Special Police Station S.O.G., District ATS & SOG, Jaipur for offences under Sections 420, 467, 468, 471 and 120-B of the Indian Penal Code, 1860 (for short, ‘IPC’). 2. Since both these bail applications arise out of the same FIR, they were heard together and are being decided by this common order. 3. Learned counsel for the accused-petitioners submits that the petitioners have falsely been implicated in the present case and no evidence is available on record connecting them with the alleged offence of preparation of forged degrees, manipulation of records or issuance of fabricated documents. It is contended that the prosecution case rests primarily upon omnibus allegations and assumptions without any specific overt act being attributed to the petitioners. Learned counsel submits that petitioner-Jogendra Singh had already resigned from the concerned institution in the year 2015 and, therefore, had no connection with the alleged admissions, examinations or issuance of degrees pertaining to the examination conducted in the year 2022 and despite the same, he has been implicated merely on account of his past association with the University. [2026:RJ-JP:21963] (3 of 14) [CRLMB-5690/2026] 3.1. Whereas, so far as petitioner- Sangeeta Kadwasra @ Bhoomi is concerned, it is submitted that no specific allegation exists regarding preparation of forged documents and no incriminating recovery has been effected from her possession connecting her with the alleged offences. It is further contended that the allegations relating to forged signatures and handwriting are unsustainable inasmuch as FSL examination regarding the disputed signatures had already been conducted during investigation conducted in FIR No.13/2024 and no separate investigation on the same aspect survives in the present matter. 3.2. Learned counsel further submits that the present FIR has been lodged on substantially identical allegations i.e., alleged irregularities in B.P.Ed. degrees and Physical Education Teacher Recruitment Examination-2022 (for short, ‘PET Exam, 2022’) which already form subject matter of FIR No.13/2024 registered at Police Station S.O.G., Jaipur, wherein charge-sheet No.09 A/2024 dated 30.09.2024 has already been filed before the competent Court and the present FIR is merely an offshoot of the earlier investigation. 3.3. It is argued that the investigating agency cannot repeatedly register multiple FIRs on the basis of the same material so as to subject the accused persons to repeated investigations, successive arrests and prolonged incarceration, which amounts to ‘evergreening of arrest.’ In support of the said contention, reliance has been placed upon the judgments passed by the Hon’ble Apex Court in the matter of: T.T. Antony Vs. State of Kerala & Ors., (2001) 6 SCC 181; Amitbhai Anilchandra Shah Vs. CBI & [2026:RJ-JP:21963] (4 of 14) [CRLMB-5690/2026] Anr., (2013) 6 SCC 348; Binay Kumar Singh Vs. State of Jharkhand & Ors., 2026 SCC OnLine SC 208 and Uday Chand Vs. Sheikh Mohd., (1983) 2 SCC 417. 3.4. Learned counsel further submits that petitioner-Jogendra Singh had already been enlarged on bail by the Co-ordinate Bench in principal FIR No.13/2024 vide order dated 06.02.2026 (S.B. Criminal Misc. 3rd Bail Application No.12723/2025), whereas petitioner-Sangeeta Kadwasra @ Bhoomi was enlarged on bail by the Hon’ble Supreme Court vide order dated 24.04.2026 passed in SLP (Crl.) No.5205 of 2026 and interim protection was also granted to the accused petitioners by the High Court at Principal Seat at Jodhpur vide order dated 27.03.2026 in S.B. Criminal Misc. Petition No.2152/2026 and other connected petitions with regards to present FIR. It is submitted that despite accused- petitioners having been enlarged on bail in the earlier FIR, they have again been arrested in the present FIR arising out of the same set of allegations. 3.5. Lastly, it is contended that no recovery remains to be effected from the petitioners, the accused petitioners are in custody since long, there is no likelihood of absconding or tampering with the prosecution evidence and the further trial of the case is likely to take considerable time, therefore, the present bail applications deserve to be allowed. 4. Per contra, learned Public Prosecutor and learned counsel appearing for the complainant have opposed the bail applications and submitted that the present case pertains to a deep-rooted and organized conspiracy involving large-scale issuance of forged [2026:RJ-JP:21963] (5 of 14) [CRLMB-5690/2026] educational degrees and mark-sheets by OPJS University, which were subsequently utilized for securing appointments in government service through the PET Exam, 2022. 4.1. Learned counsel submits that although the University had recognition for limited intake in the B.P.Ed. course, thousands of candidates were illegally issued degrees and mark-sheets in violation of statutory norms and National Council for Teacher Education regulations. It is contended that in the PET Exam 2022, alone 1359 candidates possessing B.P.Ed. degrees from OPJS University had applied despite the sanctioned intake capacity being only 100 seats per academic session and several such candidates were ultimately selected in government service. It is further submitted that admissions were granted without counselling, records were manipulated, backdated entries were created and forged educational documents were issued after receiving monetary consideration through an organized inter-state network involving University officials, brokers and other co- accused persons. 4.2. Learned Public Prosecutor further submitted that petitioner- Jogendra Singh, being the founder and controlling authority of OPJS University, played a central role in the alleged conspiracy and the investigation has collected substantial material including digital evidence, call detail records, WhatsApp chats and documentary material indicating his coordination with co-accused persons, whereas petitioner-Sangeeta Kadwasra @ Bhoomi was actively associated with the accounts and administrative [2026:RJ-JP:21963] (6 of 14) [CRLMB-5690/2026] functioning of the University and handling matters relating to records, admissions and operational management. 4.3. It is further contended that the present FIR operates in a distinct factual domain and specifically concerns candidates who secured appointments in the PET Exam, 2022 on the basis of forged educational qualifications, whereas FIR No.13/2024 pertains to broader aspects of the conspiracy and other connected transactions and, therefore, the present FIR cannot be treated as a successive FIR barred in law. It is also contended that the accused-petitioners are involved in multiple criminal cases of similar nature and considering the gravity of the offence and societal impact, the present bail applications deserve dismissal. 5. Heard Learned counsels for the parties and perused the material available on record. 6. At the outset, this Court deems it appropriate to refer to the principles regarding permissibility of multiple FIRs laid down by the Hon’ble Apex Court in the case of State of Rajasthan v. Surendra Singh Rathore, 2025 SCC OnLine SC 358, wherein it was observed as under:- “9. From the above conspectus of judgments, inter alia, the following principles emerge regarding the permissibility of the registration of a second FIR: 9.1 When the second FIR is counter-complaint or presents a rival version of a set of facts, in reference to which an earlier FIR already stands registered. [2026:RJ-JP:21963] (7 of 14) [CRLMB-5690/2026] 9.2 When the ambit of the two FIRs is different even though they may arise from the same set of circumstances. 9.3 When investigation and/or other avenues reveal the earlier FIR or set of facts to be part of a larger conspiracy. 9.4 When investigation and/or persons related to the incident bring to the light hitherto unknown facts or circumstances. 9.5 Where the incident is separate; offences are similar or different.” (Emphasis Supplied) 6.1. The aforesaid principles makes it clear that a subsequent FIR is permissible where it discloses a rival version, counter-complaint or arises out of fresh facts, new circumstances or a larger conspiracy which had not surfaced at the time of registration of the earlier FIR. 6.2. Similarly, the Hon’ble Apex Court in a very recent case of Amit Katyal & Anr. v. State of Haryana & Anr., 2026 INSC 509 decided on 18.05.2026, has held as under:- “24. In such a situation, the principle laid down in T.T. Antony v. State of Kerala (Supra), as consistently reaffirmed in subsequent decisions of this Court, squarely applies, inasmuch as there cannot be multiple FIRs in respect of the same occurrence or transaction giving rise to cognizable offences. The scheme of the Code of Criminal Procedure postulates a single, comprehensive investigation, with liberty to the investigating agency to conduct further investigation and file supplementary reports, rather than permitting parallel and overlapping investigations in different fora. [2026:RJ-JP:21963] (8 of 14) [CRLMB-5690/2026] 25. Permitting multiple FIRs and investigations in different jurisdictions on the same set of facts would not only be contrary to the settled legal position but would also result in avoidable multiplicity of proceedings, conflicting findings and serious prejudice to the petitioners. At the same time, consolidation of such FIRs at one place would subserve the ends of justice by ensuring a coordinated, effective and complete investigation, while also safeguarding the right of the petitioners to mount an effective and meaningful defence in a singular proceeding.” 6.3. This Court is also mindful of the fact that, there may be situations where, during investigation of a particular FIR, the investigating agency comes across material disclosing commission of a distinct and independent offence altogether unconnected with the original occurrence, thereby justifying registration of a fresh FIR and consequential arrest of the accused in the subsequent case; take for instance, during investigation of one offence found involvement of the accused in another independent offence of a completely different nature or reveals a larger conspiracy, then in that case, registration of a separate FIR may be legally permissible in light of the principle laid down in the case of Surendra Singh Rathore (Supra). 6.4. 6.4. It is also to be borne in mind that whether the subsequent FIR discloses a distinct offence or merely reiterates substantially identical allegations arising out of the same transaction is a question which is to be determined in light of the peculiar facts and circumstances of each case. There cannot be a straightjacket formula that can be applied in this regard as each case requires careful scrutiny of the nature of allegations, continuity of [2026:RJ-JP:21963] (9 of 14) [CRLMB-5690/2026] transaction, identity of parties, overlap of evidence and the foundational facts forming basis of the subsequent FIR. 7. In the aforesaid backdrop, the issue as to whether the accused-petitioners have been repeatedly subjected to successive FIRs and arrests on the same substratum of allegations has to be examined in light of the facts emerging from the present FIR as well as the conclusions drawn during investigation in the principal FIR No.13/2024. 7.1. The complainant in the principal FIR No.13/2024 registered at Police Station S.O.G., Jaipur, has alleged that he had applied for direct recruitment to the post of Physical Training Instructor and appeared in the PET Exam, 2022, but could not succeed and subsequently came to know that backdated and forged degrees had allegedly been issued in favour of several candidates who participated in the said examination. 7.2. The FIR further alleges that the Rajasthan Public Service Commission had invited applications for recruitment to the post of Librarian in the year 2024, and similar irregularities regarding the issuance of backdated degrees by officials of OPJS University had surfaced therein as well. During the investigation, the investigating officer, upon examining the records received from the Rajasthan Staff Selection Board about candidates who appeared in the Physical Teacher Recruitment Examinations conducted in the years 2018 and 2022, found that different result dates were reflected in the mark-sheets issued to students belonging to the same academic session of the B.P.Ed. course. The [2026:RJ-JP:21963] (10 of 14) [CRLMB-5690/2026] investigation further concluded that such degrees and mark-sheets were allegedly issued with backdated entries in exchange for monetary consideration. 7.3. The investigating officer further concluded that the large- scale issuance of such forged and backdated degrees did not align with the sanctioned intake capacity. As a consequence, several candidates were selected for appointment to the State Government service based on such forged and backdated degrees. The investigation further revealed that the University administration had allegedly granted admissions on a large scale without proper counselling and in violation of the admission rules governing the B.P.Ed. course and, despite repeated communications, OPJS University failed to furnish the accreditation documents as well as the B.P.Ed. records about the years 2018 and 2019. It has also come to light that, although the University claimed that the relevant records were destroyed in a fire in the record room, no satisfactory explanation was furnished for how verification of students' documents was subsequently carried out despite the alleged destruction of records. 7.4. The instant FIR alleges that the claim regarding the destruction of records in a fire incident dated 28.12.2019 at OPJS University is false and fabricated, since, despite the alleged destruction of records, the University continued to verify educational degrees and documents of candidates. The FIR further alleges that a large number of candidates were fraudulently selected for State Government service based on forged and backdated degrees issued beyond the prescribed intake capacity [2026:RJ-JP:21963] (11 of 14) [CRLMB-5690/2026] and timelines, thereby indicating large-scale manipulation and violation of the B.P.Ed. admission rules framed by the State Government. 7.5. A conjoint reading of the present FIR and the charge-sheet filed in principal FIR No.13/2024 prima facie reveals that the investigation conducted in the principal FIR appears to have substantially dealt with the explanation offered by the petitioners regarding destruction of records in the alleged fire incident and the investigating officer had concluded that such explanation was unsatisfactory, particularly when officials of OPJS University had subsequently proceeded to verify educational degrees and documents. The allegations in both the FIRs pertain substantially to the alleged irregularities in the PET Exam, 2022, and the issuance of B.P.Ed. degrees by OPJS University and appointments allegedly secured based on such forged and backdated degrees. Thus, the foundational facts, nature of allegations, and material relied upon in the present FIR appear to be substantially overlapping with the subject matter already investigated in principal FIR No. 13/2024. 7.6. Furthermore, the charge-sheet in principal FIR No.13/2024 came to be filed on 30.09.2024, wherein the investigating agency had already examined the explanation offered by the petitioners regarding destruction of records in the alleged fire incident and had found the same to be unsatisfactory and self-contradictory, particularly when officials of OPJS University had subsequently proceeded to verify educational degrees and documents despite claiming that the relevant records stood destroyed. [2026:RJ-JP:21963] (12 of 14) [CRLMB-5690/2026] 7.7. The present FIR thereafter came to be registered on 20.02.2026, nearly two years after the filing of the charge-sheet in FIR Number 13/2024 and during the entire intervening period, the investigating agency was fully aware that the accused- petitioners were already in judicial custody in connection with principal FIR No.13/2024 and were available for investigation at all relevant times. Despite the same, no satisfactory explanation has been placed on record justifying the delayed registration of the present FIR and the subsequent arrest of the petitioners therein, which prima facie appears to have resulted in continued deprivation of their personal liberty through successive FIRs arising out of substantially overlapping allegations. 7.8. It is also pertinent to observe that an allegedly false or unsatisfactory explanation regarding the destruction of records, by itself, would not constitute a distinct and independent offence, but may at best constitute one of the circumstances sought to be relied upon by the prosecution in support of its existing case. Therefore, considering the aforesaid facts, this Court does not find that any distinct or substantially new facts have subsequently surfaced to justify registration of the present FIR. Therefore, the arrest of the accused petitioners in the present FIR, prima facie, raises serious concerns regarding the misuse of the investigative process and prolonged deprivation of personal liberty through successive prosecutions. 8. In view of the foregoing discussion, particularly when the present FIR does not prima facie discloses any new or distinct [2026:RJ-JP:21963] (13 of 14) [CRLMB-5690/2026] facts beyond those already investigated earlier, the subsequent arrest of the accused-petitioners appears to be unwarranted and contrary to the settled principles of law, therefore, this Court deems it just and proper to enlarge the accused-petitioners on bail. 9. Accordingly, these bail applications under Section 483 BNSS are allowed and it is ordered that the accused-petitioners namely; 1. Jogendra Singh S/o Shri Omprakash and 2. Sangeeta Kadwasara alias Bhoomi D/o Shri Dharamveer Singh in connection with FIR No.12/2026, registered at Special Police Station SOG, District ATS & SOG Jaipur, shall be enlarged on bail provided they furnish a personal bond in the sum of Rs.50,000/- with two sureties of Rs.25,000/- each to the satisfaction of the learned trial Judge for there appearance before the court concerned on all the dates of hearing and as and when called upon to do so. The learned trial Judge shall also verify the addresses and the contact details of the surety through concerned S.H.O. before releasing the accused-petitioners on bail. 9.1. The accused-petitioners are directed to mark their presence on 25th of every month before the concerned Police Station till conclusion of the trial. The SHO of the concerned Police Station is directed to maintain a regular register marking the presence of the aforementioned accused-petitioners and shall send the presence report on the same day to the concerned trial Court every month without any delay. 9.2. The accused-petitioners are further directed to submit their present addresses along with their mobile numbers to the [2026:RJ-JP:21963] (14 of 14) [CRLMB-5690/2026] concerned S.H.O. within 7 days from their release and the concerned S.H.O. shall verify the said addresses and the mobile numbers. In case if the accused-petitioners changes their addresses or mobile numbers they shall submit the same before the concerned S.H.O. and also before the concerned learned trial Court. In case of any breach of the aforementioned conditions, the learned Public Prosecutor shall be free to move the application against the accused-petitioners for cancellation of the bail before the concerned Court. 9.3. A copy of this order shall be sent to the concerned S.H.O. for its strict compliance. 10. However, it is made clear that the observations made hereinabove are only for the purpose of deciding the present bail applications and shall have no bearing on the merits of the case. (PRAVEER BHATNAGAR),J Ramesh Vaishnav/86 165/166