2026 Supreme(Raj) 412

HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR
SANJEEV PRAKASH SHARMA, CJ, SANGEETA SHARMA, J.
Dr. Sangeeta Arya, W/o Niranjan Arya - Appellant
Versus
The State Of Rajasthan – Respondent 
D.B. Special Appeal Writ No. 1364 of 2025, D.B. Special Appeal Writ No. 1074 of 2025, D.B. Special Appeal Writ No. 1075 of 2025, B. Special Appeal Writ No. 1076 of 2025, D.B. Special Appeal Writ No. 1080 of 2025, D.B. Special Appeal Writ No. 1209 of 2025, D.B. Special Appeal Writ No. 1210 of 2025, D.B. Special Appeal Writ No. 1282 of 2025, D.B. Special Appeal Writ No. 1311 of 2025, D.B. Special Appeal Writ No. 1334 of 2025, D.B. Special Appeal Writ No. 1346 of 2025, D.B. Special Appeal Writ No. 1347 of 2025,D.B. Special Appeal Writ No. 1378 of 2025, D.B. Special Appeal Writ No. 1405 of 2025,D.B. Special Appeal Writ No. 1406 of 2025, D.B. Special Appeal Writ No. 1417 of 2025,D.B. Special Appeal Writ No. 1464 of 2025, D.B. Civil Writ Petition No. 13601 of 2025
Decided On : 04-04-2026

When a recruitment process is demonstrably vitiated by systemic fraud or mass malpractice, rendering the segregation of tainted and untainted candidates impractical, the court is justified in ordering the cancellation of the entire process to uphold the sanctity and legitimacy of public employment.

Headnote:(A) Recruitment Law - Cancellation of selection process - Systemic irregularities - When irregularities in a recruitment process are of a large scale and permeate the integrity of the entire examination, the decision to cancel the process is legally justified. (Paras 94, 107)

(B) Appellate Jurisdiction - Judicial review - Expert committee reports serve as advisory tools and do not substitute the court’s responsibility to apply its mind - Courts possess the plenary authority to independently assess evidence and reach conclusions based on constitutional principles. (Paras 90, 93)

(C) Writ Jurisdiction - Suppression of material facts - The non-disclosure of prior legal proceedings does not mandate the dismissal of a petition unless the suppressed fact holds a direct, substantive bearing on the merits of the current controversy. (Paras 85, 86)

(D) Admissibility of Evidence - Relevance - Evidence that is relevant to the core issues of a dispute is generally admissible, and its exclusion solely on the basis of its source of procurement is not required unless there is an express legal prohibition. (Paras 87, 88)

Facts of the case:
A public recruitment process was challenged due to allegations of widespread paper leaks and systemic fraud. The lower court ordered the cancellation of the entire examination, leading to appeals by the authorities and various selected candidates. The investigation indicated that multiple organized networks compromised the integrity of the process, coupled with lapses in examination security, surveillance, and procedure. The appellants argued that the entire process should not be cancelled at the cost of successful, untainted candidates.

Findings of Court:
The investigation revealed deep-rooted systemic failures in the recruitment mechanism. The leakage of information was widespread through various communication channels, making it impossible to identify and surgically isolate tainted candidates from the legitimate ones. Consequently, the court found the authenticity and confidentiality of the entire selection process irredeemably vitiated.

Issues: Whether the systemic nature of the irregularities justified the cancellation of the entire recruitment process, whether the court could rely on evidence procured through informal channels, and whether the omission of prior litigation in the pleadings warranted the rejection of the writ petition.

Ratio Decidendi: Where a recruitment process is vitiated by systemic fraud, the court's priority is to maintain the purity and integrity of the selection system. When manipulation is broad and permeates the foundational level of an examination, segregation becomes a theoretical exercise that cannot guarantee fairness. Therefore, the cancellation of the entire process is a necessary, albeit unfortunate, measure to protect the public interest and maintain the sanctity of recruitment, as the requirement for a fair selection process takes precedence over the interests of individuals.

Result: Appeals dismissed; the judgment of the lower court upholding the cancellation of the recruitment process is affirmed.

Table of Content
1. procedural history and factual background of the challenged recruitment examination. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 17 , 18)
2. parties' contentions regarding maintainability, res judicata, and evidentiary support for cancellation. (Para 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 32 , 33 , 34 , 35 , 36 , 37 , 38 , 39 , 40 , 41 , 42 , 43 , 44 , 45 , 46 , 47 , 48 , 49 , 50 , 51 , 52 , 53 , 54 , 55 , 56 , 57 , 58 , 59 , 60 , 61 , 62 , 63 , 64 , 65 , 66 , 67 , 68 , 69 , 70 , 71 , 72 , 73 , 74 , 75 , 76 , 77 , 78 , 79 , 80 , 81)
3. admissibility of evidence, maintainability of petitions, and status of expert reports. (Para 82 , 83 , 84 , 85 , 86 , 87 , 88 , 89 , 90 , 91 , 92 , 93)
4. assessment of systemic examination failure and infeasibility of candidate segregation. (Para 94 , 95 , 96 , 97 , 98 , 99 , 100 , 101 , 102 , 103 , 104 , 105 , 106 , 107)
5. impact of institutional malpractice on the sanctity of competitive recruitment processes. (Para 108 , 109 , 110 , 111 , 113 , 114 , 115 , 116)
6. final orders upholding cancellation and dismissing pil in service matters. (Para 117 , 118 , 119 , 120)

JUDGMENT :

SANJEEV PRAKASH SHARMA, CJ.

1. The judgement passed by the learned Single Judge dated 28.08.2025 in S.B. Civil Writ Petition No.13806/2024: Kailash Chand Sharma and Ors. Vs. The State of Rajasthan and Ors. and other connected matters is challenged before us in these bunch of special appeals preferred by the State of Rajasthan namely D.B. Civil Special Appeal (Writ) No.1346/2025: The State of Rajasthan and Anr. Vs. Kailash Chand Sharma and Ors. and another D.B. Special appeal has been filed challenging the order passed by the learned Single Judge in bunch of writ petitions in lead case of Suraj Mal Meena and Ors. Vs. The State of Rajasthan and Ors.: S.B. Civil Writ Petition No.16031/2025 whereby, directions were issued to the State Government to consider relaxation of age to the candidates who appeared in the recruitment examination of the Sub Inspector/Platoon Commander recruitment and applied in pursuance of the advertisement and reapplied under the subsequent advertisement for the same post of Sub Inspector and Platoon Commander. Other directions have also been issued by another Single Bench.

2. The learned Single Judge in his judgement dated 28.08.2025 issued the following directions:

“134. In furtherance of the noted conclusion regarding the inherent and absolute need for the cancellation of the process undertaken by the RPSC for recruitment of candidates on the post of Sub-Inspector in pursuance of Advertisement No. 08/2021 dated 03.02.2021, this Court, in agreement and in the same breath as the recommendations deemed necessary by the learned Advocate General in his opinion dated 14.09.2024, deems it fit to direct as under:-

(i) That the Government should prepare a detailed report with supporting material, in consonance with the shortcomings noted in the preceding discourse, and on that basis and along with that report and corroborating material, recommend to the RPSC to cancel the whole recruitment process conducted till date including the result/recommendations of the Sub-Inspector Police/Platoon Commander Recruitment Examination 2021.

(ii) That the RPSC should also be instructed to re-conduct the whole process under the same advertisement dated 03.02.2021, or by making alternative arrangements in the novel advertisement so issued vide notification dated 17th July 2025, on the basis of valid applications received in pursuance of that advertisement, deadline of which is September 08 2025. It would be expected from the RPSC, that in confirmation with Clause 4 of the recommendations dated 28.06.2025, to protect the interests of the candidates involved in the present recruitment process, sufficient number of posts should be advertised in the upcoming new recruitment examination and relaxation in age eligibility should also be considered positively.

(iii)Th

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