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2026 Supreme(Online)(Chh) 16938

HIGH COURT OF CHHATTISGARH AT BILASPUR
Bibhu Datta Guru, J
UTKARSH CHANDRAKAR – Appellant
Versus
CENTRAL BUREAU OF INVESTIGATION – Respondent
MCRCA No. 493 of 2026



Advocates:
For the Appellants/Petitioners: Mateen Siddique, Ashutosh Mishra
For the Respondents: Vaibhav A. Goverdhan

Anticipatory bail may be denied in cases of organized scams involving the leakage of competitive examination papers, where evidence suggests the applicant's role was integral to the conspiracy, as such offences gravely undermine the fairness and transparency of public recruitment processes.

Headnote:The applicant sought anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023, in connection with offences under Sections 120-B and 420 of the Indian Penal Code and Sections 7, 7A, and 12 of the Prevention of Corruption Act, 1988. The case involves a large-scale scam in the State Service Examination (2020–2022) where confidential question papers were leaked for illegal gratification. The court found that the applicant allegedly acted as an intermediary, collecting substantial sums of money and facilitating the distribution of leaked materials to candidates at various resorts and hotels. The primary issue was whether the applicant's role was merely logistical or integral to the criminal conspiracy. The court reasoned that statements recorded under Section 164 Cr.P.C. and documentary evidence regarding transportation and accommodation bookings strongly corroborate the applicant's active involvement in the execution of the conspiracy. The court observed that the leakage of competitive examination papers strikes at the root of fairness and transparency in public recruitment, thereby undermining public faith in such institutions. Accordingly, the application is rejected.

Table of Content
1. allegations of a large-scale conspiracy to leak public service examination papers for illegal gratification. (Para 1 , 2 , 3)
2. contention over whether the accused's role was merely logistical support or an integral part of the conspiracy. (Para 4 , 5)
3. corroboration of active involvement through witness statements under section 164 cr.p.c. and documentary evidence. (Para 6 , 7 , 8 , 9 , 10 , 11)
4. the gravity of exam leakage offences and their impact on the integrity of public recruitment processes. (Para 12 , 13 , 14 , 15 , 16)
5. denial of anticipatory bail based on the seriousness of allegations and the specific role of the applicant. (Para 17 , 18)

Digitally signed by RAHUL JHA D 20a 2te 6: .05.05 13:32:45 +0530

(Cause-title taken from Case Information System)

C A V Order

1. The present application has been preferred by the applicant/accused under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023 seeking grant of anticipatory bail, as he is apprehending his arrest in connection with Crime No. RC1242024A0004 registered at Police Station CBI, Raipur, District Raipur (C.G.) for the offences punishable under Sections 120-B and 420 of the Indian Penal Code and Sections 7, 7A and 12 of the Prevention of Corruption Act, 1988.

2. The present case emanates from a large-scale scam relating to the conduct of the State Service Examination by the Chhattisgarh Public Service Commission (PSC) during the period 2020–2022. It is the case of the prosecution that during the said period, the then Chairman of the PSC, in connivance with other officials and private persons, entered into a criminal conspiracy to manipulate the recruitment process by leaking confidential question papers of the preliminary as well as mains examinations in lieu of huge illegal gratification. The modus operandi, as revealed during investigation, indicates that selected candidates were identified in advance, money was collected through intermediaries, and the question papers along with model answers were provided to such candidates prior to the examinations. For the purpose of executing the conspiracy, arrangements were made for assembling candidates at specific locations, including marriage halls and resorts, where they were provided with leaked question papers and were made to prepare for the examinations. It is further revealed that such candidates, on the basis of leaked material, were able to qualify the examinations, thereby defeating the very purpose of a fair and transparent selection process. The investigation has further disclosed that the said conspiracy involved a nexus between public officials and private intermediaries, resulting in grave prejudice to a large number of deserving aspirants.

3. The present applicant has been arraigned as an accused in the supplementary charge-sheet dated 01.01.2026. As per the prosecution case, the applicant acted as an intermediary and facilitator in execution of the conspiracy. It is alleged that the applicant contacted one Dr. Vikas Chandrakar and assured him that candidates could be selected in the PSC examination upon payment of ₹50–60 lakhs. It is further alleged that the applicant collected money from various candidates, arranged their accommodation at Siddhi Vinayak Palace prior to the preliminary examination, and supplied them with printed question papers along with answers on the night preceding the examination. It is also alleged that after the preliminary examination, the applicant arranged transportation of candidates through a booked bus and facilitated their stay at Barnawapara resort and subsequently at Hotel Venkatesh International, Raipur, where they were made to prepare for the mains examination using leaked material.

4. Learned counsel for the applicant would submit that the applicant is innocent and has been falsely implicated. It is contended that the applicant is neither a public servant nor connected with the PSC machinery and has no role in pre

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