IN THE HIGH COURT OF JHARKHAND

(CRIMINAL MISCELLANEOUS JURISDICTION)

A.B.A No. /2022

Krishna Murari Singh Petitioner

VERSUS
Union of India through CBI Respondent

MOST RESPECTFULLY SHOWETH:

Brief facts of the Case:
1. That, a case in RC4(A)/2013 was registered on 30-04-2013 by Central
Bureau of Investigation (CBI), Anti-Corruption Branch (ACB), Ranchi
against two public servants namely (i) Sh. Gopal Prasad Singh, the then
Member, Jharkhand Public Service Commission (JPSC), Ranchi (ii) Smt.
Alice Usha Rani Singh the then Secretary, JPSC and one private person
namely ShDhiraj Kumar, M/s Global Informatics, Nirjalya Bhawan, Ranchi
u/s 120-B, 420, 468, 471 of IPC and 13(2) r/w 13(1)(d) of PC Act, 1988.
This case was registered as an outcome of Preliminary Enquiry PE
4(A)/2012-R, CBI, ACB, Ranchiwhich was registered by taking over of the
PE 34/2010, Vigilance Bureau, Jharkhand in compliance to the orders
dated 14-06-2012 of Hon’ble Jharkhand High Court (passed in Writ Petition
(PIL) No. 3594 of 2011). This Preliminary Enquiry was registered by the
Vigilance Bureau, Jharkhand to look into allegations of gross irregularities
committed in the selection process of lecturers for different universities of
Jharkhand through Jharkhand Eligibility Test (JET) - 2006 and the
interview conducted thereof for final selection of lecturers.

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2. It has been alleged in the FIR that the accused public servants namely (i)
Sh. Gopal Prasad Singh, the then Member, JPSC and (ii) Smt. Alice Usha
Rani Singh, the then Secretary, JPSC alongwith private person i.e. (iii)
Dhiraj Kumar of M/s Global Informatics, Nirjalya Bhawan, Ranchi entered
into a conspiracy among themselves and in furtherance of it committed
criminal misconduct in examination of Jharkhand State Eligibility Test i.e.
JET and also in the process of selection of lecturers for different
universities of Jharkhand by extending favour to ineligible candidates. It
has been further alleged that the public servants of JPSC, Ranchi in
conspiracy with Dhiraj Kumar (private person) dishonestly and fraudulently
manipulated / allowed to manipulate the Merit list, Assessment Charts etc.
of the examination / interview conducted for the selection and appointment
of lecturers for the different universities of Jharkhand, through “Jharkhand
Eligibility Test (JET), 2006” and interview and extended undue benefit to
their preferred candidates.
3. Investigation revealed that Sh. Dilip Kumar Prasad, the then Chairman
JPSC in criminal conspiracy with the other Members of JPSC namely Sh.
Radha Gobind Nagesh, Smt. Shanti Devi and Sh. Gopal Prasad Singh and
Smt. Alice Usha Rani Singh, the then Controller of Examination, JPSC
alongwith Sh. Dhiraj Kumar (private person) fraudulently carried out the
entire process of both the examinations i.e. (i) JET 2006 and (ii) the
interview for lecturership. The entire process was found to be tainted with
fraud and the ultimate beneficiaries of the fraud happened to be the
influential candidates, who were either declared successful in the JET 2006
examination or finally recruited as Assistant Professors in either of three
Universities i.e. (i) Ranchi University, Ranchi (ii) SiddhuKanhuMurmu
University, Dumka and (iii) Vinoba Bhave University, Hazaribagh by
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 ignoring the merit of deserving candidates. There occurred large scale
bungling in the selection process by scuttling the performance of
meritorious candidates and by accommodating influential candidates.
4. Investigation revealed that the Jharkhand Public Service Commission
(JPSC), Ranchi recommended appointment of 722 lecturers in the three
Universities namely (i) Ranchi University, Ranchi (ii) Vinoba Bhave
University, Hazaribagh and (iii) SiddhuKanhuMurmu University, Dumka on
14-01-2008. The recommendation was based on the interview conducted
by the JPSC for recruitment of lecturers during the year 2007. The eligibility
criteria for the candidates appearing in the said interview included inter alia
the successful candidates of JET 2006 (conducted by the JPSC in 2006) or
candidates having qualified NET, Ph.D or any other State Level Eligibility
Test. As such, the instant case involves two separate examination process
i.e. (i) the Jharkhand Eligibility Test (JET) conducted by the JPSC through
its advertisement No 1-JET dated 19-7-2006 which made the candidates
eligible for the post of lecturer and (ii) Interview for selection of the lecturers
conducted by the JPSC through Advertisement no. 1/2007.
5. Investigation revealed that both the exams were conducted in complete
violation of JPSC Rules of Procedure, 2002. In the JPSC Rules of
Procedure, 2002, Rule 4 (xii) (f) mandates coding of the Answer sheets
before sending it for evaluation in order to avoid exercise of influence and
nepotism by the evaluators but this was not followed. The Rule 4 (xii) (i) of
JPSC 2002 Rules, in order to ensure transparency, lays down that the
Merit List was required to be scrutinized by a Committee of three Members
nominated by Chairman whereas in the instant case, the detailed Merit
Lists for both the exams were not even available on record before
publishing the final result.
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6. That, investigation revealed the following with respect to the two
examination process:-
JET Exams conducted by the JPSC in 2006
Investigation revealed that the Jharkhand Eligibility Test (JET), 2006
examination was conducted by the Jharkhand Public Service Commission
in consultation with the University Grants Commission (UGC) and the
Department of Human Resource Development, Jharkhand Government in
the year 2006. The JPSC published Advertisement No. 1-JET dated 19-7-
2006 in newspapers across India calling for the application form. The last
date for receipt of duly completed application forms at the respective test
centres i.e (i) Ranchi University, Ranchi (ii) Vinoba Bhave University,
Hazaribagh (iii) SiddhuKanhuMurmu University, Dumka was 19-8-2006. It
was directed that the candidates should submit their applications forms
alongwith draft (payable to the JPSC) to the Registrar of the respective
Universities from where they wish to appear in the test in the 18 subjects.
Investigation revealed that the scheme of the test consisted of three
papers. All the three papers were held on the same day in two separate
sessions. Paper I and Paper II consisted of a 50 objective type questions
each and the candidate had to mark their response for each question on
the optical mark reader (OMR) sheet. Paper III consisted of only
descriptive question from the subject selected by the candidate. The
candidate was required to attempt question in the space provided in the
test booklet. As per the guidelines “A candidate who does not appear in
Paper I will not be permitted to appear in Paper II and Paper III. Paper III
will be evaluated only for those candidates who are able to secure the
minimum qualifying marks in Paper I and Paper II.

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 The JET examination was conducted on 15-10-2006 at the centers of
Ranchi, Dumka and Hazaribagh and the Deputy Commissioners of each
District were appointed as the Chief Coordinator for conducting the exams.
The sealed packets of answer books were sent to the JPSC through
authorized officials of the respective DCs.
Investigation revealed that pre & post examination work of Jharkhand
Eligibility Test was assigned to the National Cooperative Consumer’s
Federation of India Limited having its office at Adarsh Nagar, Kanke Road,
Ranchi which let out the said work through its registered agency M/s
Global Informatics, Nirjalay Bhawan, TangraToli, Pisca More, Ratu Road,
Ranchi having its Director as Dhiraj Kumar (private person and FIR named
accused person). Scrutiny of Paper I and Paper II was carried out by this
agency and also scrutinized the marksheets of Paper III. Instances have
surfaced in which the Marks Foil signed by the evaluators and the
coordinators, mentioning the marks scored by the candidates, were
received by Dhiraj Kumar in violation of the JPSC Rules of Procedure,
2002.
Investigation revealed that the final results of JET 2006 examination
were decided by Moderation Committee in the Meeting held on 12-01-2007
and 13-01-2007 during which the total number of candidates required to be
selected in each of the 18 subjects was finalised.
Investigation revealed that the result of the JET-2006 (767
candidates) was dishonestly published on 13-01-2007 on the basis of note
put up by Smt Alice Usha Rani Singh, the then Secretary cum Controller of
Examination duly forwarded by Sh. Gopal Prasad Singh, the then Member,
JPSC (Chairman of JET Cell) and approved by Sh. Dilip Kumar Prasad,

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the then Chairman JPSC (all notingsdated 13-01-2007) in absence of any
Merit List.
Investigation revealed that the results of JET 2006 were prepared in
complete violation of the laid down norms that was published in the
advertisement. In order to cause undue favour, the answer sheets in some
instances were also evaluated who did not qualify in Paper I and Paper II
even though the Advertisement clearly mentioned that “Paper III will be
evaluated only for those candidates who are able to secure the minimum
qualifying marks in Paper I and Paper II”. Moreover, even though it was
required that the Merit List/Result was to be prepared on the basis of
marks obtained in the Paper III of the candidates who qualified in the
Paper I and II, instances have surfaced in which candidates securing less
marks in the Paper III were fraudulently declared qualified ignoring
candidates who got higher marks in this paper.
Investigation revealed that in some instances, the Marks Foil signed
by the evaluators and the coordinators, mentioning the marks scored by
the candidates, were received by Dhiraj Kumar (Pvt. person and FIR
named), which is in clear disregard of the laid down procedure which states
that the sealed packets of answer books was to be received by the JPSC
in immediate supervision of Smt. Alice Usha Rani Singh, the then
Controller of Examination, JPSC. The rules also required that the manner
of dispatch of the answer sheets to the examiner and then to the Head
Examiner shall be decided by the Controller of Examination after obtaining
approval of the Chairman. The Merit List was required to be prepared by
the official Programmer of the JPSC in the immediate supervision of the
Controller of Examination but the same was fraudulently prepared by Sh.

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Dhiraj Kumar in conspiracy with the public servants of JPSC who
accommodated undeserving candidates at the cost of deserving ones.
It is revealed that no formal letter for individual evaluators was issued
by the JPSC for evaluation of the answer books and the evaluators were
chosen as per discretion. Further it is revealed that they had acquaintance
with the JPSC officials, who assigned the work of evaluation of answer
books to them. Furthermore, the Code Cutting of the answer books was
not done and the portion containing the Roll number was not detached
from the answer books when evaluator had received the same for
evaluation. The marks were mentioned by evaluators on the Marks Foil
against the Roll numbers of the candidates.
During the course of investigation, the JPSC informed that the
original answer books i.e. OMR sheets of Paper I and Paper II were not
available in their office record. The JPSC provided the Marks Foil
containing the marks scored by the candidates in Paper III of each subject
as declared by the evaluators duly signed by Coordinators as well as
Evaluators. During the course of Enquiry of PE 4 (A)/2012-R, the officials of
the JPSC reconstructed the Merit List of the JET Examination 2006 on the
basis of the Marks Foil and other available documents. The reconstructed
Merit List by the officials of the JPSC revealed that 191 candidates out of
767 candidates securing less marks were fraudulently qualified in the
results published by the JPSC on 13-01-2007. 37 out of those 191
candidates were subsequently appointed as lecturers following interviews
on the basis of eligibility attained through fraudulent JET results. It includes
Bivekanand Singh, brother of Gopal Prasad Singh (the then Member JPSC
and Chairman of the JET Cell) and Kanti Kumari, sister of Shanti Devi (the
then Member of the JPSC).
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 Lectureship Interview conducted by the JPSC in 2007
Investigation revealed that the JPSC published the advertisement for
recruitment of lecturers in consultation with the Department of Higher
Education, Jharkhand State on the basis of requisitions received from
Ranchi University, Vinoba Bhave University and Siddhu Kanhu Murmu
University regarding the vacancies available in their universities. The
Advertisement no. 01/07 for appointment to the post of lecturers was
published on 30-01-2007 in the leading newspapers with the last date of
receipt of the application forms as 28-02-2007. The total number of
vacancies advertised for three universities was 828.
Investigation revealed that the Advertisement required the applicants
for the post of lecturers having excellent academic records with minimum
55% marks in the Post-Graduation for the subject applied for. The eligibility
criteria was any of following qualification: Ph.D./ M.Phil./ JET (Jharkhand
State Eligibility Test)/ NET/ SLET(other state). The Desirable Qualification
was that the candidate should have Degree with Honours in the concerned
subject.
Investigation revealed that Smt. Alice Usha Rani Singh, the then
Secretary, JPSC issued order dated 29-03-2017 which formed the basis of
marking criteria of the applicants for preparation of the Merit list. As per this
order, the selection was based on assessment of candidates on the basis
of marks scored by them out of total 100 marks. 60 marks (out of the 100
marks) was allotted for Educational Qualification and 40 marks (out of 100
marks) was allotted for interview. It was also decided that the 60 marks
assigned for Educational qualification was to be decided on the basis of
marks secured in Matric/Higher Secondary, Inter/DI/Previous, Bachelor
(Hons. and Pass) and Post-Graduation.
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 Investigation revealed that 40 marks were allocated for the interview
to be conducted by a Board having three Experts (of the particular subject)
under the Chairmanship of one JPSC official. Dr. Dilip Kumar Prasad, the
then Chairman JPSC, issued the Order dated 29-3-2007 through which
four boards were constituted.
Investigation revealed that the interview of the eligible candidates
started from 29th March 2007 and concluded on 04-12-2007. Each of the
boards consisted of four members out of which three were experts of that
subject and the fourth i. e. the Chairman of the Board happened to be one
of the Members from the JPSC. The Chairman of each of the Board that
conducted the interview were either (i) Dr. Gopal Prasad Singh, the then
Member, JPSC (ii) Dr. Shanti Devi, the then Member JPSC (iii) Sh. Radha
Gobind Singh Nagesh, the then Member, JPSC and (iv) Sh. Dilip Kumar
Prasad, the then Chairman, JPSC.
Investigation revealed that during the course of interview, blank
Assessment Charts containing the names of the candidates (with Roll
numbers) were issued to each of the Experts and also to the Chairman of
the Board. Each Expert and the Chairman mentioned the marks awarded
by him to the candidates as per his individual assessment and signed the
Assessment Chart. In order to calculate the marks obtained by the
candidate in the interview, the average of the marks awarded by the
Experts/Chairman as mentioned in the four Assessment Charts was
considered. Dr. Dilip Kumar Prasad, the then Chairman, JPSC dishonestly
issued the order dated 29-03-2017 and directed the Secretary, JPSC to
deliver all the charts (secret documents) to the concerned agency i. e. Sh.
Dhiraj Kumar of M/s Global Informatics for preparing the Merit List in clear
violation of JPSC Rules of Procedure 2002 to extend undue favour to the
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 preferred candidates.
During the course of investigation, the Assessment Charts of the
candidates, their personal folders containing application alongwith
enclosures and the Merit List were seized to identify the instances of the
selection of tainted candidates. The instances of overwriting/manipulation
in the Assessment Charts were detected, which were sent to the CFSL for
ascertaining the actual marks awarded to the candidates. The concerned
Experts were examined who proved tampering/manipulation made in the
Assessment Charts in order to fraudulently inflate the marks of the
candidates for dishonestly selecting them.
7. Investigation revealed that Sh. Gopal Prasad Singh, the then Member,
JPSC; Smt. Alice Usha Rani Singh, the then Secretary cum Controller of
Examination, JPSC; Dilip Kumar Prasad, the then Chairman, JPSC; Sh.
Radha Govind Nagesh, the then Member, JPSC and Smt. Shanti Devi, the
then Member, JPSC in criminal conspiracy with each other and with others
with dishonest intention overlooked the procedural violations of the rules of
JPSC for conducting JET 2006 and interview for selection of lecturers,
circumvented the laid down procedures and selected ineligible and
undeserving candidates fraudulently and dishonestly.
8. After conclusion of investigation, chargesheet was filed on 25.09.2019
against accused persons namely (1) Sh. Gopal Prasad Singh, (2) Smt.
Alice Usha Rani Singh, (3) Sh. Dhiraj Kumar, (4) Sh. Dilip Kumar Prasad,
(5) Sh. Radha Govind Nagesh, (6) Smt. Shanti Devi, (7) Jindar Singh
Munda, (8) Suchitra Bara, (9) SuprabhaTuti, (10) Bharti Kumar, (11)
Amitabh Bharti, (12) Anju Pushpa Baa (13) Raghbendra Kumar Singh, (14)
MamtaKarketta, (15) Bhim Ram, (16) Binay Kumar, (17) Ashok Kumar
Singh, (18) Rajendra Singh, (19) Kanti Kumari, (20) Asim Anupam Dean,
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 (21) Santosh Swarup Shandilya, (22) Archana Sinha, (23) Sashi Kiran, (24)
Pradeep Kumar, (25) Vinod Kumar, (26) Geetanjali Singh, (27) Rakhi Rani,
(28) Radha Singh, (29) Kamal Kishor Singh, (30) Shailender Kumar
Singh, (31) Arvind Kumar Jha, (32) MamtaKujur, (33) Anmol Amar Baba,
(34) Ganesh Kumar Ram, (35) Suman Kumar, (36) Hari Prakash Jha, (37)
Prakash Chandra Das, (38) Vinod Kumar Sinha, (39) Deepnarayan Singh,
(40) Manish Kumar Dubey, (41) Baleswar Ram, (42) Shtrughan Kumar
Pandey, (43) Suresh Singh Munda, (44) Surender Kumar, (45) Rose
Oraon, (46) Kamna Roy, (47) Bivekanand Singh, (48) Krishna Murari
Singh, (49) Mantosh Kumar Pandey, (50) Vijay Aind, (51) Anita Alda, (52)
Manish Dayal, (53) Preeti Kamal, (54) Avinash Singh, (55) Satish Kumar
Singh, (56) Dhruva Narayan Singh, (57) Manoj Kumar Tiwari, (58) Snigdha
Kumari, (59) HarilalRabidas, (60) Ajay Bahadur Singh, (61) Rajendra
Kumar Baraik, (62) Jitendra Harijan, (63) Ganga Nath Jha, (64) Sanjeev
Kumar, (65) Shilpi Baxi, (66) Kedar Nath Tiwari, (67) Nalini Kant Mishra,
(68) Chandreswar Prasad and (69) M/s Global Informatics u/s 120-B r/w
201, 420, 468 & 471 IPC and Sec 13(2) r/w 13(1)(d) of PC Act, 1988 in the
light of evidence against them.
9. Evidence against Krishna Murari Singh, Asst. Professor of English in
Vinoba Bhave University.
It is humbly submitted that the accused petitioner, was declared selected
on the basis of 46 marks for his career and 29.25 marks for interview i.e.,
total 75.25 marks. However, the CFSL deciphered that this candidate has
been marks (i) 28 by one experts has been manipulated to 38 in the
assessment chart, which was later manipulated. (ii) 30 by two experts has
been manipulated to 36. He deserve only 23.75 marks in the interview.
The candidate deserves only 40 marks out of the 60 marks on the basis of
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 his Academic Qualification whereas he was illegally awarded 46 marks in
order to cause undue favour to this candidate. Krishna Murari Singh in his
application from has declared 57% in Class X he has been illegally
marked 10 out of 10 instead 7 out of 10. Similarly he has mentioned only
41% in the Intermediate as such he deserves 4 out of 10 but he has been
given 7 out of 10. As such the accused petitioner deserves only 63.75
marks, whereas minimum marks required was 75. He had been declared
successful through tampering. Hence, accused petitioner had not qualified.
He was illegally appointed as Lecturer in English in Vinoba Bhave
University.
10. Para-wise Reply to Grounds in the Petition:
i. In reply to averments made in Para 1, Para-3 and Para-4 it is submitted
that this is matter of record. Hence no comment is required.
ii. In reply to averments made in Para 2, it is submitted that this is the
knowledge of petitioner, hence no comment is required.
iii. In reply to averments made in Para 5,and Para-6, and it is submitted that
the averments made are false and misleading, hence, denied. It is further
submitted that the entire process of the selection for the post of lecturer
has been found to be tainted in order to benefit the favored candidates.
During investigation it was found that the accused petitioner was one of
them who were dishonestly and fraudulently declared successful in the
JPSC 2007-2008 examination. The Chairman and Members of JPSC,
Interview Board Members and others co-accused persons in criminal
conspiracy selected undeserving candidates for the post of lecturer
including the accused petitioner.
iv. In reply to averments made in Para 7, Para-8, and Para 9, and it is
submitted that the averments made are false and misleading, hence,
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 denied. It is humbly submitted that the accused petitioner, was declared
selected on the basis of 46 marks for his career and 29.25 marks for
interview i.e., total 75.25 marks. However, the CFSL deciphered that this
candidate has been marks (i) 28 by one experts has been manipulated to
38 in the assessment chart, which was later manipulated. (ii) 30 by two
experts has been manipulated to 36. He deserve only 23.75 marks in the
interview. The accused petitioner deserves only 40 marks out of the 60
marks on the basis of his Academic Qualification whereas he was illegally
awarded 46 marks in order to cause undue favour to this candidate.
Krishna Murari Singh in his application from has declared 57% in Class X
he has been illegally marked 10 out of 10 instead 7 out of 10. Similarly he
has mentioned only 41% in the Intermediate as such he deserves 4 out of
10 but he has been given 7 out of 10. As such the accused petitioner
deserves only 63.75 marks, whereas minimum marks required was 75.
v. In reply to averments made in Para 10, and Para-11 it is submitted that this
is matter of record. Hence no comment is required.
vi. In reply to averments made in Para-12 it is submitted that this is known to
petitioner. Hence no comment is required.
vii. In reply to averments made in Para 13, Para 14, Para 15, and Para 16, it is
submitted that this is matter of record. Hence no comment is required.
viii. In reply to averments made in Para 17, it is submitted that this is the order
of High Court. Hence no comment.
ix. In reply to averments made in Para 18 to Para 21, it is submitted that the
averments made is misleading, hence denied. The Chairman and
Members of JPSC, Interview Board Members and others co-accused
persons in criminal conspiracy selected undeserving candidate for the post
of lecturer including the accused petitioner. After thoroughly investigation,
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 the Chargesheet was filed against the accused person including the
accused petitioner u/s 120-B r/w201/420/468/471 of IPC and Sec 13(2) r/w
13(1)(d) of P.C. Act 1988.
x. In reply to averments made in Para 22 and Para 23, it is submitted that
the averments made are false and misleading, hence denied. It is humbly
submitted that the accused petitioner, was declared selected on the basis
of 46 marks for his career and 29.25 marks for interview i.e., total 75.25
marks. However, the CFSL deciphered that this candidate has been marks
(i) 28 by one experts has been manipulated to 38 in the assessment chart,
which was later manipulated. (ii) 30 by two experts has been manipulated
to 36. He deserve only 23.75 marks in the interview. As such the accused
petitioner deserves only 63.75 marks, whereas minimum marks required
was 75.
xi. In reply to averments made in Para 24 Para 25, and Para-26 it is
submitted that the averments made are misleading, hence denied. After
thoroughly investigation, the Chargesheet was filed against the accused
person including the accused petitioner u/s 120-B r/w201/420/468/471 of
IPC and Sec 13(2) r/w 13(1)(d) of P.C. Act 1988.
xii. In reply to averments made in Para-27 to 30, it is submitted that this is
known to petitioner. Hence no comment is required.
xiii. In reply to averments made in Para 31 (I to X), it is submitted that the fact
and circumstances of this case is different and the referred case laws are
not applicable to this case.
xiv. In reply to averments made in Para-32 to 36, it is submitted that the
averments made are false and misleading, hence denied. The Chairman
and Members of JPSC, Interview Board Members and others co-accused
persons in criminal conspiracy selected undeserving candidate for the post
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 of lecturer including the accused petitioner by way of alteration in the
evaluation sheet in order to provide wrongful gain to accused petitioner .
xv. In reply to averments made in Para-37 to 40, it is submitted that the
averments made are false and misleading, hence denied. It is humbly
submitted that the accused petitioner, was declared selected on the basis
of 46 marks for his career and 29.25 marks for interview i.e., total 75.25
marks. However, the CFSL deciphered that this candidate has been marks
(i) 28 by one experts has been manipulated to 38 in the assessment chart,
which was later manipulated. (ii) 30 by two experts has been manipulated
to 36. He deserves only 23.75 marks in the interview. As such the accused
petitioner deserves only 63.75 marks, whereas minimum marks required
was 75 for selection.
xvi. In reply to averments made in Para- 41,& Para-44, it is submitted that the
averments made are false and misleading, hence denied. The Chairman
and Members of JPSC, Interview Board Members and others co-accused
persons in criminal conspiracy selected undeserving candidate for the post
of lecturer including the accused petitioner. The Chargesheet was filed
against the accused person including the accused petitioner u/s 120-B
r/w201/420/468/471 of IPC and Sec 13(2) r/w 13(1)(d) of P.C. Act 1988.
Accused petitioner was wrongfully and dishonestly selected on the basis of
tempered/altered marks awarded by three experts in the Assessment
Chart.
xvii. In reply to averments made in Para- 42, It is submitted that this is
submission of accused petitioner, hence no comment,
xviii. In reply to averments made in Para- 43, It is submitted that this is matter of
law, however, accused petitioner committed crime in conspiracy with other
co-accused persons in order to get his selection dishonestly.
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xix. In reply to averments made in Para- 45, It is submitted that this is matter of
record, hence no comment,
xx. In reply to averments made in Para- 46, It is submitted that Hon’ble Court
of Ld. A.K.Mishra No. 1 Spl. Judge CBI, Ranchi has passed a just and
reasoned order while dismissing the anticipatory bail application of the
accused petitioner.
xxi. In reply to averments made in Para 46, to Para 51, it is submitted that the
averments made are false and misleading, hence, denied. Chargesheet
was filed against the accused person including the accused petitioner u/s
120-B r/w201/420/468/471 of IPC and SEC 13(2) r/w 13(1)(d) of P.C. Act
1988. He is an influential person which is evident from the fact that he
succeeded in his fraudulent selection after entering into criminal conspiracy.
Hence, there is likelihood of his tempering with the evidence, influences the
witnesses.
PRAYER

In view of the above facts, It is most humbly prayed that and this
Hon’ble Court may pleased to reject the petition in the interest of justice.

Respondent

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