Partly allowed

Roshanlal Meena S/O Narayan Meena v. State of Rajasthan

Rajasthan HC18 Aug 2025CRLMB/15796/2024

Case brief

AI extract

What is this about?

Bail applications in an SOG case alleging Roshanlal appeared as a dummy candidate for Deepak in the Sub-Inspector recruitment exam 2021, with Mahesh conspiring to facilitate it. The court dismissed bail for Roshanlal and Deepak citing six identical cases and criminal antecedents but granted bail to Mahesh on conditions.

What did the court decide?

Mahesh Kumar Meena released on bail on personal bond of ₹50,000 with two like sureties subject to conditions; bail applications of Roshanlal Meena and Deepak Kumar Meena dismissed.

Roshanlal Meena S/O Narayan Meena Vs State of Rajasthan — Cheating and Forgery | Rajasthan HC (2025)

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[2025:RJ-JP:34225]

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HIGH COURT OF JUDICATURE FOR RAJASTHAN BENCH AT JAIPUR

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S.B. Criminal Miscellaneous Bail Application No. 15796/2024

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Roshanlal Meena S/o Narayan Meena, Aged About 33 Years, R/o Maanpuriya Kothya, P.s. Nangal Rajawatan, District Dausa (Currently Tritiya Shreni Adhyapak (Level-First), Mahatma Gandhi Vidyalaya, Pyarivaas , Dausa. (Presently Accused Petitioner Is Confined In Central Jail, Jaipur)

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----Petitioner

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Versus

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State Of Rajasthan, Through P.p

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----Respondent

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Connected With

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S.B. Criminal Miscellaneous Bail Application No. 15795/2024 Deepak Kumar Meena S/o Hemraj Meena, R/o Indaawa, Tehsil Lalsot, District Dausa. (Presently Accused- Petitioner Is Confined In Central Jail, Jaipur)

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----Petitioner

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Versus

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State Of Rajasthan, Through P.p

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----Respondent

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S.B. Criminal Miscellaneous Bail Application No. 15797/2024 Mahesh Kumar Meena S/o Teekaram Meena, R/o Phoolwada, Gangapur Tehsil Bamanwas, District Sawai Madhopur. Presently, Clerk Grade Second/ Junior Assistant Office Of Commercial Tax Office, Circle Dausa (Presently Accused- Petitioner Is Confined In Central Jail, Jaipur.)

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----Petitioner

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Versus

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State Of Rajasthan, Through P.p

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----Respondent

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For Petitioner(s)	: Mr. Deepak Chauhan with Mr. Harsh Joshi & Mr. Ashok
	Choudhary
	Mr. Gajveer Singh Rajawat
For Respondent(s)	: Mr. Vijay Singh Yadav & Ms. Arti Sharma,PP

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Mr. Haripal Singh, CI, SOG, Jaipur

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HON'BLE MR. JUSTICE ASHOK KUMAR JAIN Order

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18/08/2025

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These three bail applications were preferred by applicantsaccused Roshanlal Meena S/o Narayan Meena, Deepak Kumar Meena S/o Hemraj Meena and Mahesh Kumar Meena S/o Teekaram Meena in a matter arising out of FIR No. 31/2024 dated 24.05.2024 lodged at P.S. Special Police Station (SOG) District ATS and SOG, Jaipur under Sections 419, 420, 467, 468, 471, 120-B of IPC and 3, 4, 6 of Rajasthan Public Exam (Use of Unfair Means) Act, 1992.

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Learned counsels for the parties submits that applicantaccused Deepak is a candidate who applied for the recruitment of Sub-Inspector of Police Joint Competitive Examination, 2021 but as per SOG, instead of appearing himself as a candaidate, accused Roshan Lal has been engaged to appear as a dummy candidate on behalf of Deepak in the Examination. They further submit that Mahesh Kumar has no concern either with Deepak or Roshan but an allegation is made against him that he conspired with his nephew Deepak and other accused so as to facilitate Roshan Lal in appearing as a dummy candidate in the said Examination. They further submits that after investigation, a charge-sheet has been filed against all three persons and looking to the list of witnesses and documents submitted by Investigating Agency, it is not likelihood that the trial will complete within statutory time as prescribed under the law.

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Learned counsels for the applicants further referred the provision of Rajasthan Public Examination (Prevention of Unfair Means) Act, 1992 (hereinafter referred as “Act of 1992” ) and submits that the maximum punishment is 3 years and the offences are triable by Magistrate. They further submit that the evidence on record is insufficient even to frame charge against any of the applicant. They further submits that the examination was held on 13.09.2021 and FIR is registered only in 2024 without explaining the reasons of delay.

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Learned counsel appearing on behalf of Deepak and Mahesh submits that Deepak and Mahesh are uncle and nephew ( MamaBhanja) and they are closely related with each other. He further submits that it is not possible for them to indulge in financial transactions and to conspire with any third party to engage and facilitate a dummy candidate. He further submits that both of the them were granted bail in two cases. He also submits that Deepak has qualified in the written examination but he was not selected in subsequent physical test and ultimately he was not selected as a candidate. He further referred money transaction between year 2018 to 2020 and submitted that same cannot be connected with the exam held on 13.09.2021 as the time lapse is not matching with the schedule of exam conducted by RPSC. He further submits that further money transaction is reported from May, 2022 to February, 2024 and that too of petty amount, which indicate that after several months of the examination a candidate or a person allegedly associated with the exam has received money in instalments, for work completed on 13.09.2021. He further

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submits that these money transactions are not sufficient evidence to show link between the applicants. He further referred FSL report particularly handwriting and submits that SOG has sent handwriting opinion of Deepak and Roshan for examination by FSL and the report clearly indicate that it is matching nearly 72% wih Deepak (more than 2/3 of total words). He explained in detail the FSL report to the Court and submit that same is not sufficient to conclude that Roshan Lal has appeared on behalf of Deepak as a dummy candidate. At last, he submits that Deepak and Mahesh are in custody since 14.10.2024, and trial has not begin so far.

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Learned counsel appearing on behalf of Roshan submits that he is an innocent person and there is no evidence to show his involvement as a dummy candidate. He also relied upon FSL report and submits that either from attendance sheet or from OMR Sheet nowhere it is established that this applicant-accused has appered as a dummy candidate on behalf of Deepak. He further submits that handwriting report is just an opinion and it is not a conclusive proof. He also referred the evidence collected by SOG and submits that the small and petty transaction from ₹1000/- to ₹50,000/- between Deepak and Roshan Lal were mentioned as a rewarded money for appearance as a dummy candidate on behalf of Deepak but this transaction is from year 2018 to 2020 and further the transactions are from 2022 to 2024 but there is no transaction in year 2021. He further submits that nowhere it is established that applicant-accused is involved in identical nature of offences, and applicant is in custody since 24.07.2024.

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Learned counsel for applicants submits that Hon’ble Supreme Court has granted bail on ground of length of custody.They further referred Girdhariram Vs. State of Rajasthan SLP (Criminal) No. 7461/2025 (Order dated 23.06.2025) passed by Hon’ble Supreme Court and order in case of bail application No. 15988-89 of 2024 and order dated 08.08.2025 in bail application No. 191/2025 & 192/2025.

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Aforesaid contentions were opposed by learned Public Prosecutor and submits that these applicants are involved in other cases and having a criminal background.

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Heard learned counsels for the applicants and learned Public Prosecutor. Perused the material placed on record. Also considered the report submitted by SOG.

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The facts of the case clearly indicate that during investigation, in FIR No. 11/2024 dated 01.04.2024 applicantaccused Roshan Lal has disclosed that he has appeared as a dummy candidate on behalf of Deepak Kumar Meena in SubInspector of Police Joint Competitive Examination, 2021 organized by RPSC, Ajmer. On basis of this information, SOG has investigated the matter and registered an FIR No. 31/2024 and after investigation filed a charge-sheet against Roshan Lal, Deepak and Mahesh but kept pending against Manish Kumar, Dinesh Kumar and another under Sections 173(8) of Cr.P.C.. The applicant-accused Roshan Lal is arrested on 24.07.2024. Accused Deepak and Mahesh were arrested on 04.10.2024. Since, then applicants-accused are in custody.

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The examination was conducted on 13.09.2021 and as per investigation, Roshan Lal appeared as a dummy candidate and impersonated himself as Deepak Meena in said examination. We have considered the material available on record particularly with reference to Roshan Lal, Deepak and Mahesh Kumar. The matter pertains to the offence under the Act of 1992. This Court has granted bail to Mahesh and Deepak on 08.08.2025 in FIR No. 21/2024 dated 09.05.2024 registered at SOG, District ATS and SOG. Similarly, Deepak and Mahesh Kumar were granted bail by a Co-ordinate bench on 20.01.2025 in FIR NO. 22/2024 registered at P.S. SOG. In case of Girdhariram Vs. State of Rajasthan (supra) Hon’ble Supreme Court has granted bail to the accused, who was in custody since 18.04.2024 and only on ground of length of custody allowed the bail.

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Herein, this case as per record 6 identical nature of cases were registered against Roshan Lal and we have dismissed the bail application of Roshan lal in FIR No. 21/2024 P.S. SOG on 08.08.2025. As per list submitted by SOG, 6 cases were registered against Deepak Kumar. When we connect then it appears that Roshan Lal and Deepak Kumar were involved in same FIR. This fact is brought on record that Roshan Lal is working as Grade-III Teacher in Mahatama Gandhi Government School Pyariwas, District Dausa. Accused Deepak Kumar was declared successful in written examination held on 13.09.2021 but he was not selected thereafter in physical test. We have considered the grounds as raised by learned counsel for applicants.

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Six criminal cases were registered against Manish Kumar and we have considered his role in the matter as he is found involved in same FIR with Deepak and Roshan Lal. Admittedly, Deepak and Mahesh Kumar are Mama-Bhanja and the report of SOG suggested that Roshan Lal was driven by Deepak Kumar to Centre at Bhilwara. The involvement and role of Mahesh Kumar is for entering into a conspiracy, to help Deepak. The list of cases registered against the applicants clearly indicate that all these applicants are involved in same six cases. In two cases Mahesh and Deepak were released on bail and two cases are pending today for consideration of bail.

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We have considered the material as forwarded by SOG with charge-sheet. The transaction detail is between Roshan Lal and Deepak Kumar though, same is prior to 2021 and after 2021 and there is no transaction trail of year 2021. The transaction amount is too small on multiple occasions, which also signifies friendship between accused persons.

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Having considered the totality of facts and circumstances of the case, I am of the considered view that Roshan Lal and Deepak Kumar are the main accused in the instant case wherein Deepak Kumar is a candidate and he did not appeared in person as a candidate in the said examination and engaged Roshan Lal who appeared as dummy candidate. Roshan lal is a teacher and allegation upon him is to appear for financial gain. The applicant Roshan Lal is in custody since 24.07.2024 and Deepak since 04.10.2024, though, the applicants are in custody for more than

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one year and 10 months respectfully but still there are six identical nature of cases and looking to criminal background and material available against them on record, I am of the view that it is not appropriate to grant bail to applicants-accused Roshan Lal and deepak Kumar but considering the role and involvement including evidence available on record, it is appropriate to grant bail to applicant-accused Mahesh Kumar.

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Thus, the instant bail application filed on behalf of applicantaccused Mahesh Kumar Meena S/o Tikaram Meena , is hereby allowed and the applicant-accused Mahesh Kumar Meena is ordered to be released on bail upon furnishing a personal bond of ₹50,000/- with two sureties of like amount to the satisfaction of the Trial Court with the following conditions:-

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(i) The applicant-accused shall not tamper with evidence or influence the witness in any manner.

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(ii) The applicant-accused shall not indulge in any criminal activity and shall not repeat any criminal offence punishable under the Law.

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(iii) The applicant-accused shall attend the hearing of the Trial Court on the date fixed by the Trial court or as and when asked to appear before the Trial Court.

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(iv) In case of any violation of above conditions, the bail granted to the applicant-accused shall be liable to be canceled.

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Thus, bail application Nos. S.B. Criminal Miscellaneous Bail Application No. 15796/2024 and 15795/2024 preferred by Roshan Lal Meena and Deepak Kumar are hereby dismissed.

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The Registry is directed to send a copy of this order to the Trial Court through E-mail.

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( ASHOK KUMAR JAIN ),J

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MONU /36-38

Roshanlal Meena S/O Narayan Meena v. State of Rajasthan

Case brief

What is this about?

What did the court decide?

Roshanlal Meena S/O Narayan Meena v. State of Rajasthan

Case brief

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