Chhattisgarh High Court

Systemic malpractice and procedural irregularities in examinations justify cancellation of selection process despite absence of direct evidence.

Anand Sagar Bisi & Others v. State of Chhattisgarh & Others [WA No. 135 of 2026]

Chhattisgarh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The appellants, serving Patwaris with over five years of experience, participated in a departmental examination (2023–2024) for promotion to Revenue Inspector.

Source reference: p. 8

Out of 2600 candidates, 216 were declared successful, but training was stalled following allegations of malpractice.

Source reference: p. 8

A High-Level Investigation Committee report dated 29.11.2024 found procedural irregularities but no direct evidence of a paper leak.

Source reference: p. 8

However, the matter was referred to the ACB/EOW for a preliminary enquiry.

Source reference: p. 8

The appellants filed a writ petition seeking to join training, which was dismissed by a Single Judge on 02.01.2026.

Source reference: p. 7-10

The Single Judge not only denied the relief but declared the entire process vitiated due to signs of favoritism and directed a fresh examination.

Source reference: p. 7-10

The appellants challenged this order on the grounds that it travelled beyond the pleadings and lacked definitive proof of deeply rooted malpractice.

Source reference: p. 9
02

Issues

1. Whether the Single Judge erred in cancelling the entire selection process based on the principle of preponderance of probabilities in the absence of direct material proving malpractice.

Source reference: p. 11

2. Whether the departmental examination was conducted in a sufficiently fair and transparent manner to warrant the promotion and training of successful candidates.

Source reference: p. 11
03

Law Applied

The Court primarily applied the principle of Preponderance of Probabilities to assess the integrity of public examinations.

Source reference: p. 11

It relied on the judicial 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—even without direct proof of individual wrongdoing—may justify the cancellation of the entire process.

Source reference: p. 12

The Court further applied the standard of review for Intra-Court Appeals, which dictates that interference is only warranted if there are "palpable infirmities" or "perversities" in the Single Judge’s order.

Source reference: p. 12
04

Reasoning

The Division Bench examined the Single Judge's reasoning, which identified several "suspicious" circumstances: the requirement of mobile numbers on OMR sheets (enabling candidate identification), the doubling of questions from 50 to 100 within the same time limit, and the allotment of consecutive roll numbers to twenty-two close relatives.

Source reference: p. 11-12

The Court found that while direct evidence of a "leak" might be absent, these procedural lapses collectively created a reasonable doubt regarding the fairness of the exam.

Source reference: p. 11

The Bench rejected the appellants' argument regarding "legitimate expectation," noting that the integrity of the selection process is paramount.

Source reference: p. 12

It concluded that the Single Judge provided cogent and justifiable reasons to hold the process as "tainted with signs of favoritism and nepotism," and since no "palpable infirmity" was found in that judicial logic, the appellate court declined to substitute its view.

Source reference: p. 12-13
05

Holding

The Court answered the issues in the negative, holding that the Single Judge’s decision to cancel the vitiated selection process was legally sound and did not warrant interference.

The Writ Appeal was dismissed.

Source reference: p. 13

The Court upheld the liberty granted to the State to conduct a fresh, transparent examination for the post of Revenue Inspector and clarified that these observations would not prejudice any pending criminal proceedings.

Source reference: p. 7, 12

No costs were awarded.

Source reference: p. 13
Chhattisgarh High Court

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Anand Sagar Bisi & Others v. State of Chhattisgarh & Others [WA No. 135 of 2026]

Chhattisgarh High Court · no citation

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