Ramgopal Meena vs The State Of Madhya Pradesh on 23 March, 2026

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Madhya Pradesh High Court

Ramgopal Meena vs The State Of Madhya Pradesh on 23 March, 2026

1. This is the second application filed by the applicant under Section 438 of Cr.P.C/482 of B.N.S.S. for grant of anticipatory bail apprehending his arrest in connection with Crime No.74 of 2025 registered at Police Station - Cyber and High Tech Crimes, Bhopal (M.P.) for the offences punishable under Sections 61(2), 316(4), 319(2), 339, 340(2), 318(4), 336(4), 318(2) of the BNS and Section 42,66,66-C, 66-D of the Information Technology Act. Sections 111, 238, 241, and 61 of the BNS and Sections 35,36 and 42 of the Aadhar (Targeted Delivery of Financial and other subsidies, Benefits and Services) Act and Sections 3, 4 of the Pariksha Adhiniyam.

2. It is the case of the prosecution that a recruitment examination for Police Constable (PCRT-2023) was conducted in the State of Madhya Pradesh. During the course of investigation of Crime No. 74/2025 registered at Cyber Signature Not Verified Signed by: MANVENDRA SINGH PARIHAR Signing time: 25-03-2026 12:34:43 NEUTRAL CITATION NO. 2026:MPHC-JBP:24010 2 MCRC-12912-2026 Police Station, Bhopal. The present applicant was a duly selected candidate of PCRT-2023 and had joined service at PHQ, District Anuppur, and was subsequently deputed to PTS Tighra, Gwalior, for training. During investigation, the prosecution received information indicating that the applicant had made changes in his Aadhaar record near the relevant period of the examination. On scrutiny of Aadhaar update history and related digital records, suspicion arose that the said update could be connected with the larger conspiracy of impersonation and tampering of biometric data by certain candidates to secure selection fraudulently. Accordingly, a notice was issued to the applicant for appearance and production of relevant documents. The Investigating Agency asserts that custodial interrogation may be necessary to ascertain the role of the applicant, to recover relevant documents and digital evidence, and to identify other members of the alleged conspiracy.

3. Learned counsel for the applicant submits that the applicant is innocent and he has falsely been implicated in the present crime. Learned counsel for the petitioner submits that no Aadhaar details were updated with any malicious intent or conspiracy; the correction was made only to rectify clerical errors relating to the parent's name. The petitioner has passed the examination through his own hard work without adopting any illegal means. The implication of the petitioner is based merely on suspicion, and the entire case rests on documentary evidence already in possession of the investigating agency. Therefore, no purpose would be served by custodial interrogation, and the petitioner deserves the benefit of anticipatory bail. The applicant has been made accused on the basis of memorandum of co-accused Ashish Kumar. That upon receipt of the notice, the applicant immediately contacted the Investigating Officer and clarified that he had never updated his biometrics. He only corrected his father's name in his Aadhaar Signature Not Verified Signed by: MANVENDRA SINGH PARIHAR Signing time: 25-03-2026 12:34:43 NEUTRAL CITATION NO. 2026:MPHC-JBP:24010 3 MCRC-12912-2026 record, which was earlier incompletely recorded and did not tally with his educational certificates.

4. Learned Government Advocate submits that this offence is related to manipulation of Aadhar Card issued to the applicant. The applicant with conspiracy with other co-accused changed the biometric and photo in UDAI to get the benefit in the police recruitment, thus application is liable to be dismissed.

We have heard learned counsel for the parties and perused the record.

5. The accused was selected in the 2023 constable recruitment examination. He allegedly conspired with other co-accused and altered his biometrics and photograph in his UIDAI Aadhaar card. Taking advantage of this, another person appeared in the examination in his place, and the accused thereby secured the post of constable. The allegation against the accused is that he permitted impersonation in the examination to secure the post. The OMR sheet contains the thumb impression and handwriting of the person who actually appeared in the examination; therefore, comparison of the handwriting and thumb impressions is necessary to connect the accused with the offence. On the above grounds, the first application was rejected.

6. The accused admitted that he himself got his father's name changed in his Aadhaar card; however, this does not mean that he conspired with other co- accused to alter his biometrics and photograph in his UIDAI Aadhaar card. These facts are matters of evidence and will be determined by the trial court. At this stage, no conclusion can be drawn that no conspiracy was made to secure the selection.

7. Learned counsels for the applicant further submitted that this Court has granted bail on 09.12.2025 in a similar case (Crime No. 74/2025) to accused Ashish Kumar and prayed that the present application be allowed on the ground of Signature Not Verified Signed by: MANVENDRA SINGH PARIHAR Signing time: 25-03-2026 12:34:43 NEUTRAL CITATION NO. 2026:MPHC-JBP:24010 4 MCRC-12912-2026 parity.

8. A bail order cannot be treated as a precedent in other cases, even if the offence is similar. It is a settled principle that bail decisions depend upon the facts and circumstances of each case. Parity cannot be claimed as a matter of right when the roles of the accused are different. Therefore, the present application is not acceptable on the ground of parity. Further, although an accused may file a subsequent anticipatory bail application, he must demonstrate a substantial change in circumstances since the rejection of the earlier application. All the facts had already been considered while deciding the first bail application. In the present case, there is no change in circumstances. Therefore, no case is made out for anticipatory bail. Accordingly, the applicant is not entitled to anticipatory bail, and the second bail application is liable to be rejected.

9. Consequently, this MCRC stands dismissed.

                                          (VIVEK RUSIA)                                  (PRADEEP MITTAL)
                                              JUDGE                                           JUDGE
                           MSP




Signature Not Verified
Signed by: MANVENDRA
SINGH PARIHAR
Signing time: 25-03-2026
12:34:43

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Madhya Pradesh High Court