Rajasthan High Court Turns Down Bail for Duo Accused of Buying Forged FMGE Certificates

In a significant order that underscores how fraud in professional licensing exams erodes public trust, the Rajasthan High Court has dismissed bail applications filed by two young doctors accused of obtaining fake Foreign Medical Graduate Examination (FMGE) pass certificates through an elaborate conspiracy involving payments up to Rs 16 lakh.

Justice Praveer Bhatnagar, while rejecting the pleas of Piyush Kumar Trivedi and Shubham Gurjar, held that the gravity of allegations involving fabrication of examination credentials, combined with their alleged organised misuse for securing internship, justified continued incarceration despite the petitioners having spent over five months in judicial custody .

Alleged Fraudulent Path from Georgia to Internship

The petitioners, both of whom had pursued their MBBS degrees in Georgia, are alleged to have repeatedly failed the mandatory FMGE screening test required for Indian medical practice. According to the prosecution case stemming from FIR No. 34/2025 registered at Police Station SOG, Jaipur , the accused entered into a criminal conspiracy to procure fake documents instead of qualifying legitimately.

The charge-sheet filed by investigators paints a detailed picture: Piyush Kumar allegedly contacted Shubham Gurjar to arrange a forged Screening Test Pass Certificate for the December 2023 FMGE exam using the stolen roll number 2311200091. The duo, along with co-accused Devendra Singh Gurjar and Bhana Ram Saini alias Bhanu, allegedly facilitated the creation of the fake certificate, paid advance amounts, and used it to apply for internship counselling through the Rajasthan Medical Council . Piyush is said to have completed his internship on the strength of these credentials before the fraud came to light through verification by the National Board of Examinations in Medical Sciences .

Defence Claims Matrimonial Dispute and Bona Fide Belief

Counsel for the petitioners strongly argued that the FIR was lodged with malicious intent arising from personal and matrimonial disputes between the families of one of the accused and the complainant. They contended that the petitioners had no knowledge of the forged nature of the documents, which were allegedly collected and submitted by the complainant himself, who then informed them of having qualified.

Importantly, the defence highlighted that the petitioners had not themselves prepared any forged documents, investigation stood complete with a charge-sheet already filed, and both accused had been in custody since early December 2025 with no criminal antecedents . They urged that continued incarceration would serve no purpose when trial is likely to take considerable time.

Prosecution Highlights Organised Conspiracy and Societal Harm

The Public Prosecutor countered that material collected during investigation clearly established the petitioners' active role in the conspiracy. Verification revealed that the roll number used belonged to another genuine candidate, and the forged certificate was used to fraudulently obtain internship rights meant only for those who had lawfully qualified the FMGE.

“Such acts not only strike at the very root of the sanctity and credibility of competitive examinations, but also seriously prejudice the rights of genuine and meritorious candidates who compete through lawful means,” Justice Bhatnagar observed in his order.

The Court further noted the far-reaching consequences such offences have on public confidence in institutional and regulatory systems, drawing upon the Supreme Court ’s observations in State of Rajasthan Vs. Indraj Singh Etc. (2025 INSC 341) which stressed that considerations like lack of antecedents and period of custody cannot eclipse the primary offence and its effect on society.

When Custody Alone Cannot Secure Bail

The single judge carefully balanced the petitioners’ long incarceration against the nature of allegations involving fabrication of examination-related documents for securing professional opportunities. The Bench held that the manner of procurement and subsequent use of forged credentials for internship counselling warranted denial of bail without commenting on merits.

This ruling aligns with the growing judicial trend of viewing examination fraud not merely as individual wrongdoing but as an attack on the integrity of professional qualification systems. In echoing the Supreme Court ’s concern about the stark reality of “far more takers of Government jobs than there are jobs available,” the Rajasthan High Court has sent a clear signal that shortcuts compromising merit will face stringent scrutiny at the bail stage.

Practical Ramifications for Similar Cases

By declining bail, the High Court has effectively reinforced that accused persons involved in systematic manipulation of medical licensing examinations must face trial while in custody. The order is expected to guide lower courts when dealing with bail applications in cases alleging large-scale fraud concerning professional credentials across other disciplines as well.

The bail applications stand dismissed. The petitioners will continue to remain in judicial custody at Central Jail Jaipur pending trial.