Widespread systemic fraud and institutional compromise mandate the total cancellation of selection processes regardless of segregation possibilities.

The Rajasthan Public Service Commission (RPSC) issued an advertisement on 03.02.2021 for 859 posts of Sub-Inspector and Platoon Commander.

The selection involved a written exam, physical efficiency test, and interview.

After final results were declared on 01.06.2023 and appointments were issued, several unsuccessful candidates (petitioners) filed writ petitions alleging systemic malpractices, including paper leaks via organized gangs (Kaler and Jagdish gangs) and the involvement of RPSC members.

A Special Operations Group (SOG) investigation led to the arrest of 138 persons, including 51 trainee SIs and two RPSC members, Babulal Katara and Ramuram Raika.

A Single Judge of the High Court cancelled the entire recruitment process on 28.08.2025.

The State of Rajasthan and several selected (untainted) candidates appealed this decision, arguing that tainted candidates could be segregated from the innocent ones.

1. Whether the writ petition was maintainable despite the petitioners withdrawing a previous petition without liberty to file afresh.

2. Whether the non-disclosure of the earlier litigation and the allegedly unauthorized procurement of SOG reports constituted fatal suppression of material facts.

3. Whether the malpractices were systemic in nature, vitiating the entire process and rendering the segregation of tainted and untainted candidates impossible.

4. Whether a Suo Moto PIL was maintainable in service matters regarding recruitment malpractices.

The Court applied the principles governing the cancellation of competitive examinations established in Vanshika Yadav v. Union of India, which requires assessing if a breach is systemic, affects the whole integrity, and if segregation is possible.

It relied on State of West Bengal v. Baishakhi Bhattacharya (Chatterjee), holding that purity of selection is paramount and en masse cancellation is justified upon reasonable certainty of systemic malaise.

Regarding procedural conduct, it applied State (NCT of Delhi) v. BSK Realtors LLP on the materiality of suppression.

It applied Yashwant Sinha v. CBI regarding the admissibility of documents regardless of their source.

It further noted that PILs are generally not maintainable in service matters as per Dattaraj Nathuji Thaware v. State of Maharashtra.

The Court rejected the preliminary objections regarding maintainability, reasoning that non-disclosure of the 2022 petition was not "material" because it didn't distort the core issue of systemic fraud which only became evident after subsequent SOG investigations.

On merits, the Court found the examination integrity was "breached thoroughly" due to a "foundational collapse".

It noted that the leak was widespread via social media, making the "journey of a document" impossible to trace fully.

The RPSC's failure to implement internet shutdowns, biometrics, or effective videography contributed to the malaise.

Crucially, the Court highlighted the involvement of constitutional functionaries (RPSC members), whose passive silence or active collusion (allowing a known suspect to sit on interview panels) shook the judicial conscience.

The Court held that even though individual "untainted" candidates might suffer, they cannot pass muster when the process itself lacks legitimacy.

It dismissed the "separation of grain from chaff" theory, noting that after two years of investigation, the SOG still hadn't identified all beneficiaries, and pending investigations under Section 173(8) CrPC made complete segregation unreliable.

It upheld the Single Judge’s decision to cancel the Sub-Inspector/Platoon Commander Recruitment Examination 2021 in its entirety.

The Court ordered the RPSC to re-conduct the process and directed the State to consider age relaxations for original applicants.

It set aside the Single Judge’s initiation of Suo Moto PIL proceedings, holding service matters are outside PIL jurisdiction.

All appeals by the State and selected candidates were dismissed.