'Shattering Confidence Of Hardworking Youth': Orissa High Court Denies Bail To 14 Accused In ASO Exam Paper Leak

Holding the alleged act as a crime against the very social fabric, the Bench of Justice Gourishankar Satapathy held –

“Sabotaging the exam in this way by leaking the question papers and supplying the model answer sheets to the aspiring candidates definitely corrodes the morale of meritorious candidates and the allegation against the petitioner definitely reveals a crime against society, which cannot be accepted in any way and the allegation against the petitioners depicts a socio economic offence of huge magnitude and no civilized society can ever accept the leaking of question papers in recruitment examination to Government posts.”

Pursuant to a notification dated 14.05.2024 issued by the High Court establishment, the Preliminary Examination of the ASO recruitment, 2024-25 was held on 04.05.2025. The examination, which was held in Optimal Mark Recognition (OMR) model, saw attendance of 20,260 out of 32,189 registered candidates.

For conducting the said examination, M/s. Sillicon Techlab Pvt. Ltd, Bhubaneswar (“the agency”) was selected in a bidding process. Upon submission of consolidated results to the High Court, some discrepancies were found for which the agency had to reevaluate the papers.

The said agency voluntarily offered to conduct the mains written examination as well as the computer test. The mains examination was held on 13.07.2025. The agency got the answer sheets evaluated and submitted the results along with answer sheets to the High Court on 12.08.2025, informing that 2,120 candidates have come out successful.

However, the Court found large scale illegalities and breach of confidentiality and fairness on the part of the agency. Therefore, the High Court through its Registrar (Examination) lodged an FIR against the petitioners, who were some or other way connected with the agency and the examination process.

Upon investigation, a charge-sheet was filed against them for commission of offence punishable under Sections 316(2) (criminal breach of trust), 316(5) (criminal breach of trust by public servant or agent), 318(4) (cheating and dishonestly inducing delivery of property), 61(2) (criminal conspiracy), 111 (organised crime) and 3(5) (common intention) of the BNS keeping the investigation open under Section 193(9) of the BNSS. They were subsequently arrested and were denied bail by the Additional Sessions Judge, Cuttack. Being aggrieved by the denial order, they approached the High Court for bail.

The State submitted that the petitioners were instrumental in mobilizing prospective candidates of the examination and collected huge sums of money (approximately ₹2-₹4 lakhs per candidate) in exchange of the examination question paper and model hand-written answers. The candidates were allegedly lodged in certain secret coaching centres and were trained to familiarize themselves with the model answers.

Call Details Record (CDR) of certain petitioners also revealed repeated call history with some candidates. One of the prime accused had also allegedly formatted his laptop data in order to screen and destroy digital evidence. Further, it was also revealed that some of the petitioners were in past also involved in paper leaks and sabotaging the Sub-Inspector of Police Examination and Odisha Teachers Eligibility Test (OTET).

Considering the gravity of the crime against the backdrop of the prima facie available materials, the Court was of the view that the acts of the petitioners have potential to shatter confidence of hardworking youth and may imperil the social fabric itself. In the words of Justice Satapathy–

“It cannot be forgotten that competitive and public recruitment exams demand the highest standards of integrity and transparency, but in recent past malicious elements, organized paper leak syndicate, negligent service vendors have severely disrupted public exams. These paper leaks yield massive illicit financial gains for criminals while shattering the confidence of millions of hardworking youths. The leakage of public recruitment exam papers is not merely a common criminal offence; it is a direct assault on the socio-economic fabric of the society and shatters the public trust in meritocracy. The offence deprives lakhs of honest hardworking candidates of their livelihood causing deep institutional damage and public anger.”

Therefore, considering the collected evidence at the nascent stage of the case, criminal antecedents of certain petitioners, their further act of suppressing such antecedents and ultimately their role in sabotaging the entire examination process, the Court was not inclined to grant them bail. Accordingly, the bail petitions of 14 accused-petitioners were rejected.

Case Title: Sridhar Mantry & Ors. v. State of Odisha

Case No: BLAPL Nos. 1912, 1984, 2054, 2259, 2522, 2683, 2942, 2964, 3423, 3433, 3906, 4961, 5825 & 5893 of 2026

Date of Order: July 17, 2026

Counsel for the Petitioners: Mr. Dharanidhar Nayak, Sr. Advocate along with Mr. P. Nayak, Advocate & Mr. B.K. Das, Advocate; Mr. Milan Kanungo, Sr. Advocate along with Mr. S.R. Mohanty, Advocate; Mr. Soura Chandra Mohapatra, Sr. Advocate along with Mr. S. Mohapatra, Advocate; Mr. M. Khatua, Advocate; Mr. D. Nair, Advocate along with Mr. S. Mohapatra, Advocate; Mr. S.R. Panda, Advocate; Mr. B.K. Das, Advocate; Mr. D.K. Das, Advocate; Ms. C. Tripathy, Advocate; Mr. B.B. Choudhury, Advocate

Counsel for the Opposite Parties: Mr. Partha Sarathi Nayak, Specially Engaged Counsel for the State

Citation: 2026 LiveLaw (Ori) 82