Selection tainted by systemic irregularities and lack of transparency justifies cancellation of departmental examination.

In brief

The question

1. Whether the departmental examination for promotion from Patwari to Revenue Inspector was conducted in a fair and transparent manner or was vitiated by systemic compromise.

The court held

The High Court dismissed the intra-court appeal, affirming the Single Judge's order.

It also directed

The Court held that since the selection process was tainted by systemic irregularities, the Appellants had no right to be sent for training.

The State was granted liberty to conduct a fresh examination to ensure a fair selection process, while clarifying that these findings would not prejudice pending criminal proceedings.

No costs were awarded.

01Facts

The Appellants (Patwaris) challenged an order dated 02.01.2026 passed by a Single Judge in WPS No. 1739 of 2025, which dismissed their writ petition.

p. 3

The original petition sought a direction to the State to send the Appellants for training following a departmental examination held in 2023–2024 for promotion from Patwari to Revenue Inspector.

p. 3

The State had withheld training and challenged the examination's integrity based on an investigation report dated 29.11.2024, which highlighted systemic irregularities including the inclusion of mobile numbers on OMR sheets, suspicious scoring patterns, and the success of closely related candidates.

pp. 3-4

02Issues

i.1. Whether the departmental examination for promotion from Patwari to Revenue Inspector was conducted in a fair and transparent manner or was vitiated by systemic compromise.

p. 3, para 7

ii.2. Whether the Appellants were entitled to a direction for training based on their results in the contested examination.

p. 4, para 7

03Law Applied

The Court applied the "principle of preponderance of probabilities" to assess the fairness of public examinations.

p. 3

It relied on the precedents of *Vanshika Yadav v. Union of India* and *State of West Bengal v. Baishakhi Bhattacharyya (Chatterjee) & Others*, which establish that the sanctity and integrity of examinations must be preserved and that a systemic compromise justifies the cancellation of the entire selection process.

p. 4

It further clarified that doctrines of promissory estoppel and legitimate expectation do not apply when the selection process is tainted by fraud or procedural illegality.

p. 4

04Reasoning

The Division Bench adopted the reasoning from its prior judgment in *Satish Kumar Das v. State of Chhattisgarh* (WA No. 149 of 2026).

p. 3, 5

The Court analyzed the investigation report which revealed that OMR sheets required mobile numbers—a practice that enables candidate identification and compromises anonymity.

p. 3

Furthermore, the court noted "suspicious" circumstances: the examination duration remained 90 minutes while questions increased from 50 to 100, yet candidates secured near-perfect marks; and 22 close relatives were allotted consecutive roll numbers despite being from different districts.

p. 4

The Court concluded these factors cumulatively pointed toward favoritism and nepotism, rendering the process unfair and non-transparent.

p. 4

Consequently, the Court found no "palpable infirmities" in the Single Judge's refusal to grant relief.

p. 5

05Holding

The High Court dismissed the intra-court appeal, affirming the Single Judge's order.

p. 5

The Court held that since the selection process was tainted by systemic irregularities, the Appellants had no right to be sent for training.

p. 4

The State was granted liberty to conduct a fresh examination to ensure a fair selection process, while clarifying that these findings would not prejudice pending criminal proceedings.

p. 4

No costs were awarded.

p. 5

LawLens.Chhattisgarh High Court

Original Court PDF