IN THE HIGH COURT OF JHARKHAND

(CRIMINAL MISCELLANEOUS JURISDICTION)

A.B.A. /2022

Ashok Kumar 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

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 (JET) - 2006 and the interview conducted thereof for final selection of
lecturers.
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
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 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 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.

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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.
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

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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.
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).
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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, 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
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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. 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
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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).

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

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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.
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
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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
preferred candidates.
During the course of investigation, the Assessment Charts of
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 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)
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 Kanti Kumari, (20) Asim Anupam Dean, (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.

Evidence against Ashok Kumar Singh, Asst. Professor of English in

Vonoba Bhave University.

Ashok Kumar Singh was declared selected on the basis of 37 marks for his
career and 38 marks for interview i.e., total 75 marks. However, the CFSL

12
deciphered that this candidate was initially given 31 marks in the
assessment chart which was later manipulated and increased to 38.
Three experts have universally given accused petitioner 38 marks but
the Chairman has given him 31 which was tampered and made 38. Total
marks = (38+38+38+31) = 145 then average marks interview =36.25, Total
Marks received= 36.25+37=73.25 marks. As such, this candidate deserved
only 73.25 marks whereas the minimum marks required for selection was
75. And he was illegally appointed as lecturer in English.
Para-wise Reply:

1. In reply to averments made in Para 1, Para-2, and Para-3, it is

submitted that this is matter of record. Hence no comment is requied.
2. In reply to averments made in Para 2, (a) &(b) it is submitted that this
is the knowledge of petitioner. Hence no comment.
3. In reply to averments made in Para 4, this relates to F.I.R, and
chargesheet, hence no comment is required. 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 Sec.13(1)(d) of P.C.
Act 1988.
4. In reply to averments made in Para 5, it is submitted that the
averments made are false and misleading, hence, denied. It is further
submitted that 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. Chargesheet was filed against the accused
person including the accused petitioner u/s 120-B r/w Sec
201/420/468/471 of IPC and Sec 13(2) r/w 13(1)(d) of P.C. Act 1988.

13
5. In reply to averments made in Para-6, this is matter of record. Hence
no comment is required.
6. In reply to averments made in Para-7, Para -8, it is submitted that
accused petitioner was declared selected on the basis of 37 marks
for his career and 38 marks for interview i.e., total 75 marks. , it is
further submitted that three experts have universally given accused
petitioner 38 marks but the Chairman has given him 31 which was
tampered and made 38. Total marks = (38+38+38+31) = 145 then
average marks interview =36.25, Total Marks received=
36.25+37=73.25 marks. As such, this candidate deserved only 73.25
marks whereas the minimum marks required for selection was 75.
And he was illegally appointed as lecturer in English. 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.
7. In reply to averments made in Para-9, it is submitted that the
averments made are misleading, hence, denied. The page no. 82 of
charge sheet clearly shows that accused petitioner has been selected
for English subject. It is further submitted that accused petitioner has
been wrongfully selected.
8. In reply to averments made in Para-10, it is submitted that the
averments made are misleading, hence, denied.
9. In reply to averments made in Para-11, Para-12 Para-13, Para-14,
Para-15, and Para-16, Para17, and Para-18, it is submitted that this
is matter of record, hence no comment is required.
10. In reply to averments made in Para-19, it is submitted that
accused petitioner has joined the VBU at later date Order dated 2697
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 dated 4-8-2014 signed by the Secretary JPSC, Ranchi. The JPSC
was not having the original application of accused petitioner and so
the appointment letter was issued on the basis of the photocopy of
application provided by accused petitioner.

11. In reply to averments made in Para-20, to Para 27, it is

submitted that this is matter of record, hence no comment is required.
12. In reply to averments made in Para 28, it is submitted that the
averments made are misleading, hence denied. It is submitted that
the JPSC was not having the original application of accused
petitioner and so the appointment letter was issued on the basis of
the photocopy of the application provided by accused petitioner. 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. it is further submitted that three experts have universally
given accused petitioner 38 marks but the Chairman has given him
31 which was tampered and made 38. Total marks = (38+38+38+31)
= 145 then average marks interview =36.25, Total Marks received=
36.25+37=73.25 marks. As such, this candidate deserved only 73.25
marks whereas the minimum marks required for selection was 75.
13. In reply to averments made in Para 29, Para 30, and Para 31, it is
submitted that this is matter of record, hence no comment is required.
14. In reply to averments made in Para 32, to 35, it is submitted that the
averments made are 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
15
 post of lecturer including the accused petitioner. It is further submitted
that the three experts have universally given accused petitioner 38
marks but the Chairman has given him 31 which was tampered and
made 38. As such this candidate is illegally selected on the basis of
forgery in the assessment chart.
15. In reply to averments made in Para-36, to Para-41, it is submitted
that this is matter of record, hence no comment is required.
16. In reply to averments made in Para-42, to 44, it is submitted that the
averments made are misleading, hence denied. It is further
submitted that the three experts have universally given accused
petitioner 38 marks but the Chairman has given him 31 which was
tampered and made 38. As such accused petitioner is illegally
selected on the basis of forgery in assessment chart. Chargesheet
was filed against the accused person including the accused petitioner
u/s 120-B r/w Sec 201/420/468/471 of IPC and Sec 13(2) r/w 13(1)(d)
of P.C. Act 1988.
17. In reply to averments made in Para-45 to Para-49, it is submitted that
this is matter of record, hence no comment is required.
18. In reply to averments made in Para 50, it is submitted that this
matter relates to charge sheet. Hence denied. After thoroughly
investigation, the Chargesheet was filed against the accused person
including the accused petitioner u/s 120-B r/w Sec 201/420/468/471
of IPC and Sec 13(2) r/w 13(1)(d) of P.C. Act 1988.
19. In reply to averments made in Para 51, to 57, it is submitted that the
averments made are misleading, hence denied. It is further submitted
that the three experts have universally given accused petitioner 38
marks but the Chairman has given him 31 which was tampered and
16
 made 38. As such this candidate is illegally selected. Chargesheet
was filed against the accused person including the accused petitioner
u/s 120-B r/w Sec 201/420/468/471 of IPC and Sec 13(2) r/w 13(1)(d)
of P.C. Act 1988.it is submitted that the averments made are
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.
20. In reply to averments made in Para-58, it is submitted that it is
submission of accused petitioner, hence no comment.
21. In reply to averments made in Para-59 to Para-61, it is submitted that
this is matter of record, hence no comment is required.
22. In reply to averments made in Para 62, to Para-66, it is submitted that
these are submission of petitioner, hence denied. It is humbly
submitted that he has been wrongfully and dishonestly selected as
Asst. Professor. He is an influential person which is evident from the
fact, that he succeeded in his fraudulent selection after entering into
criminal conspiracy with other co-accused persons. Hence, there is
likelihood of his tempering with the evidence, and influences the
witnesses if released on bail.
PRAYER
It is most humbly prayed that accused petitioner, the accused
petitioner may not granted bail in the interest of justice.

Respondent

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