Rajasthan HC Refuses to Quash FIR Against Forest Guard Who Allegedly Used Dummy Candidate in Recruitment Exam
Justice Farjand Ali dismissed a quashing petition filed by a serving Forest Guard accused of deploying a dummy candidate in the 2020 Forest Guard Recruitment Examination, finding prima facie material warranting continued investigation.
The High Court of Judicature for Rajasthan at Jodhpur has declined to quash an FIR registered against Pramila, a woman presently serving as a Forest Guard under the office of the Deputy Conservator of Forests, Sirohi. Justice Farjand Ali, sitting singly, dismissed S.B. Criminal Miscellaneous (Petition) No. 1256/2026 on 12 May 2026, holding that the investigative material collected by the Special Operations Group prima facie disclosed ingredients of the offences alleged and that no exceptional circumstance warranted interference while investigation was still in progress. The case involves allegations that a dummy candidate appeared in Pramila's place during the written examination for the Forest Guard Recruitment Examination, 2020, conducted by the Rajasthan Subordinate and Ministerial Services Selection Board.
The FIR and the Allegations
FIR No. 56/2025 was registered on 26 November 2025 at the Special Police Station, ATS & SOG, Rajasthan. The offences alleged are punishable under Sections 419, 420, 467, 468, 471 and 120-B of the Indian Penal Code, as well as Sections 3, 6, 7 and 10 of the Rajasthan Public Examination (Prevention of Unfair Means) Act.
The SOG had been investigating allegations of dummy candidates and unfair means in the Forest Guard Recruitment Examination, 2020. During that investigation, it allegedly surfaced that another person had appeared in the written examination in place of Pramila on 13 November 2022 at B.N. P.G. Girls College, Kankroli, Rajsamand, thereby facilitating her unlawful selection to the post of Forest Guard.
The central allegation rested on a discrepancy: the photograph and signatures uploaded in the online application form did not correspond with those appearing on the admit card and examination documents. The attendance sheet and OMR records procured from the Rajasthan Staff Selection Board were said to prima facie substantiate the impersonation allegation.
The investigation also brought to light an earlier FIR — FIR No. 125/2021 — registered against Pramila for offences under Sections 419, 420, 468 and 120-B IPC in connection with the REET Examination, 2021. In that case, allegations had been levelled that a candidate named Ananya Choudhary alias Jhummee was intended to appear in place of Pramila by affixing her photograph on the admit card. The SOG's report further alleged that Pramila had concealed the pendency of FIR No. 125/2021 during police verification while securing her appointment as Forest Guard.
Pramila's Defence Before the Court
Pramila, through counsel Mr. J.K. Suthar and Mr. Shaitan Singh, sought quashment of the FIR and all consequential proceedings under Section 528 of the Bharatiya Nagarik Suraksha Sanhita, 2023.
Upon joining investigation, Pramila had asserted before the investigating agency that the alleged dummy candidate was intended to appear on behalf of her sister and not for herself. On the question of concealment, she contended that the online application form required disclosure only of prior convictions. Since no competent court had ever convicted her, she maintained that her negative response was accurate.
How the Court Reasoned
Justice Farjand Ali began by restating the scope of inherent jurisdiction under Section 528 BNSS. The Court is not expected, he observed, to embark upon a meticulous roving enquiry to adjudicate the genuineness, reliability or truthfulness of FIR allegations. That jurisdiction is to be exercised sparingly and with great circumspection, particularly where investigation into cognizable offences is still underway.
Turning to the material before him, the judge found that the allegations were not founded upon bald or omnibus assertions alone. The record prima facie reflected collection of material indicating discrepancy in photographs and signatures on examination documents, the existence of prior criminal proceedings involving similar allegations of impersonation, and concealment of those antecedents during police verification. The investigative report submitted by the Additional Superintendent of Police, SOG, dated 18 March 2026, was treated as disclosing material suggestive of organised adoption of unfair means in a public recruitment examination.
The Court addressed the nature of the offences directly. The allegations pertained to manipulation of a public examination process conducted by a constitutional recruitment body. Such offences, the judge held, “cannot be lightly brushed aside at the threshold” when a specialised agency is conducting the investigation and the collected material prima facie discloses cognizable offences.
On Pramila's defence that the dummy candidate was meant to appear for her sister, Justice Farjand Ali held that this was a matter of factual adjudication requiring appreciation of evidence. Such an exercise cannot appropriately be undertaken while exercising jurisdiction under Section 528 BNSS. At that stage, the Court's only task is to ascertain whether the allegations and material disclose commission of cognizable offences warranting continuation of investigation — and the Court found they did.
Outcome
Justice Farjand Ali dismissed S.B. Criminal Miscellaneous (Petition) No. 1256/2026, finding it devoid of merit. The stay petition and all pending applications were also disposed of. The FIR No. 56/2025 and all consequential proceedings against Pramila continue.