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2026 Supreme(Online)(Chh) 12037

IN THE HIGH COURT OF CHHATTISGARH AT BILASPUR
Parth Prateem Sahu, J
Manohar Patel – Appellant
Versus
State of Chhattisgarh – Respondent
WPS No. 813 of 2026



Advocates:
For the Appellants/Petitioners: Mateen Siddiqui
For the Respondents: Gary Mukhopadhya, Raja Sharma

In recruitment disputes, courts should avoid en masse cancellation of selection processes unless the entire system is fundamentally compromised. The legal duty is to segregate tainted candidates from honest ones to prevent innocent individuals from suffering the consequences of localized irregularities.

Headnote:(A) Administrative Law - Recruitment Process - Allegations of corruption and irregularities in physical efficiency test - Cancellation of entire selection process - Principles for interference - The court must adopt the principle of 'separation of grain from chaff' to segregate tainted candidates from honest ones rather than ordering en masse cancellation, unless the integrity of the process is compromised beyond redemption and it is impossible to distinguish between the tainted and the innocent. (Paras 15, 17, 19, 20)

(B) Writ Jurisdiction - Investigation - Direction for independent investigation - Such power should be exercised sparingly as a measure of last resort only when there is prima facie evidence of systemic failure or involvement of high-ranking officials which shakes the conscience of the Court. (Paras 24, 25)

Facts of the case:
A group of unsuccessful candidates challenged the recruitment process for lower-level uniformed posts, alleging widespread irregularities and corruption during the physical efficiency test conducted by an external agency. They sought the quashing of the selection list and a central agency investigation. The State contended that the process was transparent overall, with minimal errors that had already been rectified, and that the petitioners only challenged the process after being unsuccessful in the subsequent written examination.

Findings of Court:
The Court held that there was no evidence of pervasive corruption that would necessitate a complete cancellation of the selection process. The authorities had already taken proactive measures by investigating specific complaints and verifying records via surveillance footage. The Court determined that it is possible to identify and separate candidates who benefited from irregularities from those who were selected on merit.

Issues: The main issues were whether the entire recruitment process should be quashed due to alleged irregularities in the physical efficiency test and whether an independent central investigation into the selection process was warranted.

Ratio Decidendi: Recruitment processes should not be cancelled en masse when irregularities are localized and confined to a small fraction of candidates. The principle of proportionality applies, and courts must make every effort to segregate tainted candidates from those who attained merit, ensuring that innocent, successful candidates do not suffer for the misdeeds of a few, provided the system is not fundamentally compromised.

Result: Petition disposed of; prayer for quashing the selection process and CBI inquiry rejected, with a direction to the employer to conduct a specific inquiry into the identified candidates to determine their individual eligibility.

Table of Content
1. challenge to recruitment process based on pet irregularities. (Para 1 , 2 , 3 , 4)
2. arguments on segregating tainted from non-tainted candidates. (Para 5 , 6 , 7 , 8 , 9)
3. extent of irregularities and scope of judicial review. (Para 10 , 11 , 12 , 13 , 14)
4. principle of proportion and segregation over mass cancellation. (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22)
5. standards for directing investigation by central agencies. (Para 23 , 24 , 25 , 26 , 27)
6. directions for targeted departmental enquiry and rectifying selection. (Para 28 , 29 , 30 , 31)

CAV Order

1. Petitioners, who are applicants in the recruitment process initiated by respondent State for appointment of Constables of different trades, have filed this writ petition pleading therein that at the time of conducting Physical Efficiency Test (for short ‘PET’), respondent No.4-agency deputed by the respondent State for conducting PET, had completed PET by adopting corrupt means, benefiting some candidates and thereby there was irregularity in the selection process. They also pleaded that written examination was also not conducted in a fair and transparent manner. Hence, prayed for following reliefs:-

10.1. The Hon’ble Court may kindly be pleased to quash & set aside the whole selection process thereby also quash the impugned Final select list dated 9/11/2025 for the post of Constable (GD). [ANNEXURE P/1]

10.2. The Hon’ble Court may kindly be pleased to direct the respondent authority to initiate and conduct a fresh selection process in a proper and fair manner for recruitment on the post of Constable.

10.3. The Hon’ble Court may kindly be pleased to issue writ/ writs, directing a thorough independent investigation through CBI into the concerned matter and scam that has been done in the selection process for the post of Constable (GD).

10.4. The Hon’ble Court may kindly be pleased to grant any other relief which this Hon’ble Court deems fit and proper in favour of the petitioner as per the facts & circumstance of the present case, in the ends of justice.”

2. Learned counsel for petitioners would submit that in the year 2023 respondent State had issued an advertisement for initiating recruitment proceedings for appointment on the post of Constable of different trades. Petitioners submitted application forms for their appointment as Constable and also participated in the selection process. First stage of selection process was PET. As the petitioners are residents of Bilaspur range, their PET was organized at Sakri, District Bilaspur. According to petitioners, in conduct of PET at Sakri Centre, mass irregularities have been committed by respondent No.3 and certain officials of the Selection Committee, by increasing distance in long jump and short-put; increasing height in high jump and by reducing the time to complete the race, which adversely affected result of PET. Petitioners and others have submitted representation pointing irregularities so submitted in conducting PET, but no heed was paid to the same. In District Rajnandgaon also similar allegations were made and further allegation of giving undue advantage to some of the candidates / aspirants were also levelled. Taking note of several representations made questioning selection process as adopted during PET, a letter was forwarded by respondent No.3 to the Superintendent of Police of all the districts within the State of Chhattisgarh seeking clarification/report on the allegations made in the representations. In the letter dated 19.12.2024 (Annexure P-8) written by the Superintendent of Police, Bilaspur-cum- Chairman, Constable Selection Committee Centre-1, Bilaspur, there is mention about commission of grave irregularities by respondent No.4. Thereafter also letters were issued elaborating irregularities which were found by the Superintendent of Police, Bilaspur and in letter dated 21.1.2025, roll numbers of 54 candidates, who were found involved in irregularities, have been mentioned whic

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