Orissa HC Rejects Bail for 14 Accused in High Court's Own ASO Recruitment Paper-Leak Case
Justice G. Satapathy refused bail to all 14 accused in the Lalbag PS Case alleging systematic leakage of question papers and model answers in the High Court of Orissa's own ASO examination, 2025.
Justice G. Satapathy of the High Court of Orissa, sitting singly at Cuttack, on 17 July 2026 dismissed all 14 bail applications filed under Section 483 of the Bharatiya Nagarik Suraksha Sanhita, 2023 by persons accused of engineering a systematic paper leak in the Assistant Section Officer (ASO) Preliminary and Main Written Examinations conducted on behalf of the High Court itself. The case, registered as Lalbag PS Case No. 463 of 2025 and corresponding to GR Case No. 1047 of 2025 before the learned SDJM Sadar, Cuttack, names the accused for offences under Sections 316(2), 316(5), 318(4), 61(2), 111 and 3(5) of the Bharatiya Nyaya Sanhita. The refusal rests on the nature and gravity of the alleged offences, the prior involvement of several petitioners in a parallel SI of Police recruitment exam leak, and the suppression of that involvement from some of the bail applications.
The ASO Recruitment and the Outsourced Agency
On 14 May 2025, the High Court of Orissa issued Advertisement No. 02 of 2024 inviting applications for 147 posts of ASO, with the selection process designed in four phases: Preliminary Examination, Main Examination, Computer Test, and Viva Voce. A total of 32,239 applications were received; 32,189 candidates were found eligible for the preliminary round.
The Preliminary Examination was outsourced to M/s. Sillicon Techlab Pvt. Ltd., Bhubaneswar (“the Agency”), selected through a bidding process, at Rs. 160 per candidate including GST. The agreement was signed by Ms. Ipsita Priyadarshini as authorised representative. The preliminary examination was held in OMR mode on 4 May 2025; 20,260 out of 32,189 eligible candidates appeared.
After evaluation of OMR sheets, the Agency initially reported 7,116 qualifiers on 9 May 2025. The High Court's own Recruitment Cell found discrepancies—invalid OMR sheets had been accepted and three unqualified candidates were listed as having passed. The Agency revised the figure to 7,113 on 15 May 2025. The Agency was then contracted at Rs. 1,000 per candidate (including GST) to conduct the Main Written Examination and Computer Application Test, with petitioner Himansu Sekhar Dash signing the fresh agreement as authorised representative.
The Main Written Examination took place on 13 July 2025 at 11 centres across Khurda and Cuttack districts. The Agency submitted results on 12 August 2025 showing 2,120 successful candidates. On scrutiny, the High Court's Registrar (Examination) found large-scale illegalities compromising fairness and confidentiality. On 28 November 2025, the Registrar (Examination) lodged an FIR at Lalbag Police Station, registered as PS Case No. 463 of 2025, against petitioners Suresh Chandra Nayak, Himansu Sekhar Dash, Sridhar Mantry, Ms. Ipsita Priyadarshini and others.
What the Investigation Uncovered
Investigation revealed that several candidates had reproduced answers verbatim, matching supplied model answer sheets. Call Detail Record (CDR) analysis showed frequent communication between the accused and candidates at various stages of the examination. The prosecution's case, as reflected in the charge sheet, is that the petitioners and others in active criminal conspiracy leaked question papers before the examination and supplied model answer sheets, ultimately forcing the cancellation of the Main Written Examination.
Specifically, petitioner Sridhar Mantry, the Agency's Project Head and subject matter expert, was alleged to have personally visited Saraswati Press, Calcutta and supplied confidential examination materials—including question papers and model answers—in soft copy via pen-drive for printing. Model answer sheets were allegedly seized from his official desk, and his laptop was reportedly formatted to destroy digital evidence.
Petitioner Suresh Chandra Nayak, Director of the Agency, was alleged to have exercised overall control and to have illegally delegated the examination process to M/s. Panchsoft Pvt. Ltd. through co-accused Sankar Prusty without the High Court's approval, in clear violation of contractual conditions. Petitioner Himansu Sekhar Dash, the authorised signatory of the Agency, was alleged to have acted as an operational link between the Agency and the intermediaries for disseminating leaked question papers.
Petitioner Sankar Prusty, Director of M/s. Panchsoft Technologies Pvt. Ltd., was described by the prosecution as the mastermind who collected illegal gratification and operated tutoring centres through petitioners Alok Sahoo and Nirmalya Krushna Das for supplying question papers and answer sheets to candidates. CDR analysis of Prusty's mobile numbers allegedly showed frequent contact with beneficiary candidates, agents and co-accused persons, and his phone was switched off between 10 July 2025 and 12 July 2025.
The remaining petitioners—Gangadhar Jena, Jyotirmayee Sahoo @ Jyotirmayee Sahu, Sapan Kumar Panda, Tafim Ahemmad Khan, Ramjee Prasad Gupta, Epili Sitaram @ E. Sitaram, Lokanath Sahoo and Satya Brata Mohanty @ Milu—were alleged to have acted as intermediaries who mobilised candidates, collected advance consideration money ranging from Rs. 2 lakh to Rs. 4 lakh per candidate, retained original educational certificates as security for payment of balance amounts, transported candidates to tutoring centres at Bhubaneswar, Cuttack and Berhampur, and facilitated the distribution of handwritten model answers identical to the actual examination content.
Arguments for and against Bail
Senior Advocate Dharanidhar Nayak, for petitioner Sridhar Mantry, contended that Mantry's visit to the press was in discharge of his duties as Project Head and that no material established the question papers seized were copies of the originals. He further submitted that petitioner Sankar Prusty's role was limited to supply of manpower through Panchsoft Technologies, with no specific allegation in the FIR. Senior Advocate Soura Chandra Mohapatra, for petitioner Alok Sahoo, argued that Section 111 of BNS had been added only to prolong detention and that Sahoo had resigned from the Agency on 29 February 2024, well before the examination.
Senior Advocate Milan Kanungo, for petitioners Nirmalya Krushna Das and Himansu Sekhar Dash, submitted that Das was responsible only for logistics and CCTV camera installation. He alternatively sought interim bail for Dash to attend to his ailing sister. Counsel for Gangadhar Jena noted that only two original certificates seized from his possession had not been connected to any identified candidate. Counsel for Sapan Kumar Panda argued that the case rested on bank transaction records which had already been seized. Counsel for Ramjee Prasad Gupta asserted that despite being named in the FIR, he had no role and had been granted bail in the separate OTET case. Counsel for Suresh Chandra Nayak contended that the matter at best disclosed a contractual dispute and that criminal liability could not be fastened vicariously on a director absent a statutory provision and a specific allegation of active participation with criminal intent.
Specially Engaged Counsel for the State, Mr. Partha Sarathi Nayak, opposed bail across the board, pointing to the mobilisation of candidates for illegal gratification, Sridhar Mantry's alleged destruction of digital evidence, and the prosecution's assertion that Sankar Prusty was the mastermind. He also placed on record that petitioners Suresh Chandra Nayak, Sankar Prusty, Tafim Ahemmad Khan, Lokanath Sahoo and Epili Sitaram had been similarly implicated in a separate CBI ACB case concerning leaking of question papers in the SI of Police Recruitment Examination in Odisha.
How the Court Reasoned
Justice Satapathy rejected the contention that prolonged custody alone warranted bail. He relied on the Supreme Court's decision in State of Bihar v. Amit Kumar Alias Bachcha Rai, (2017) 13 SCC 751, where the Apex Court disapproved granting bail mechanically on the ground of prolonged custody in cases undermining the integrity of the education system.
The Court characterised the alleged conduct as a socio-economic offence of significant magnitude, observing that leaking public recruitment exam papers was not merely a common criminal offence but a direct assault on the socio-economic fabric of society, corrosive of meritocracy and damaging to the prospects of honest candidates who had prepared for the examination. The Court also observed that over 32,000 candidates had applied for 147 posts, and that more than 5,000 appeared in the Main Examination that was ultimately cancelled.
On the applicability of Section 111 of BNS, the Court declined to rule at the bail stage, noting it was premature to assess materials to reach a conclusion on that question in bail proceedings.
Regarding the interim bail plea of Himansu Sekhar Dash for his sister's treatment, the Court found no merit: the medical documents on record showed the sister had attended CMC Vellore even while Dash was in custody, was admitted to KIMS Hospital, Bhubaneswar on 13 May 2026 and discharged on 17 May 2026 with her mother signing the admission form. The Court concluded that Dash's detention was not a hindrance to her treatment.
A separate consideration weighed against several petitioners: their alleged involvement in the SI of Police Recruitment Examination leak. The Court held this prior implication to be an adverse circumstance against granting bail. Applying the Supreme Court's decision in Munnesh v. State of Uttar Pradesh, 2025 SCC OnLine SC 1319, which held that suppression of involvement in criminal cases disentitles an accused to the discretionary relief of bail, the Court noted that most of these petitioners had not disclosed their alleged prior implication in their bail applications.
Outcome
All 14 bail applications—BLAPL Nos. 1912, 1984, 2054, 2259, 2522, 2683, 2942, 2964, 3423, 3433, 3906, 4961, 5825 and 5893 of 2026—were rejected. The charge sheet has already been filed, and the investigation remains open under Section 193(9) of BNSS in respect of some accused. The trial is pending before the learned SDJM Sadar, Cuttack. The Court directed that a soft copy of the judgment be immediately transmitted to the court in seisin over the matter.