Investigation At Threshold | Andhra Pradesh HC Refuses Bail To APPSC Secretary And Contractor In Group-I Evaluation Scam Citing Need To Probe Rs 1.14 Crore Payment
Sanchayita Lahkar
The High Court of Andhra Pradesh Single Bench of Justice Kiranmayee Mandava declined to grant regular bail to two accused persons in connection with a criminal case concerning the evaluation process of Group-I examination answer scripts. The Court concluded that "the allegations leveled against the petitioner call for investigation which is at threshold stage" and thus found it inappropriate to enlarge the petitioners on bail at this juncture. The petitioners, a former Secretary of the Andhra Pradesh Public Service Commission (APPSC) and a representative of a private entity engaged in the evaluation process, were accused in Crime No. 56 of 2025 registered by Suryaraopeta Police Station, NTR District.
While rejecting the plea for regular bail, the Court noted the deteriorating medical condition of the first petitioner and permitted the accused to file an application for limited medical bail before the competent Magistrate. The Court directed the Magistrate to call for a medical report and dispose of such an application expeditiously. The bail petition filed by the second accused was dismissed in full. These directions were issued in a common order disposing of both petitions.
The petitioners in Criminal Petition Nos. 5701 and 5748 of 2025 approached the High Court under Section 439 of the Criminal Procedure Code, 1973 read with Sections 480 and 483 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023 seeking regular bail in the event of their arrest in connection with Crime No. 56 of 2025 registered by Suryaraopeta Police Station, NTR District.
The first petitioner served as the Secretary of the Andhra Pradesh Public Service Commission (APPSC), while the second petitioner is the representative of M/s. Camsign Media Private Limited, a private firm allegedly entrusted with the evaluation of answer scripts of the Group-I main examination.
The criminal proceedings stemmed from a complaint filed by Sri P. Raja Babu, IAS, against both accused. The complaint alleged that during the tenure of the first petitioner, APPSC engaged the services of a private entity for the evaluation of Group-I main examination answer scripts, contrary to standard procedures. As per the complaint, the first petitioner, acting in his official capacity, moved the answer scripts to a private facility within Haailand Resorts, Mangalagiri, and entrusted their manual evaluation to M/s. Camsign Media Private Limited, represented by the second petitioner.
APPSC had initially issued a notification in 2018 to fill 169 Group-I vacancies. The preliminary examination took place on 26-05-2019, and results were declared on 01-11-2019, qualifying 9679 candidates for the main examination, which was conducted from 14-12-2020 to 20-12-2020. Following the main examination, APPSC decided to employ digital evaluation for answer scripts. However, unsuccessful candidates challenged this decision through W.P. No. 10805 of 2021. The High Court allowed the writ petition, setting aside the digital evaluation and directing a manual evaluation.
In compliance, the first petitioner made arrangements to relocate all answer scripts to a building within Haailand Resorts and assigned their manual evaluation to M/s. Camsign, which submitted a quotation subsequently approved by the APPSC. The work order was issued, and the answer scripts remained at Haailand from December 2021 to February 2022. The APPSC paid Rs. 1,14,32,312/- to M/s. Camsign for the alleged services.
After a new Secretary assumed office, the answer scripts were retrieved from Haailand and transferred to APPSC premises and other government buildings for evaluation. This re-evaluation, done under CCTV surveillance with fresh OMR sheets, resulted in a new set of results followed by interviews and postings.
On 22-04-2025, the present Secretary of APPSC sent a letter to the Principal Secretary, Government (Services and HRM), alleging that the activities of M/s. Camsign at Haailand required deeper investigation. Consequently, Crime No. 56 of 2025 was registered on 25-04-2025.
During investigation, the second petitioner was arrested on 07-05-2025. A PT warrant was issued against the first petitioner, who was produced before court on 08-05-2025 and remanded to judicial custody.
The first petitioner’s counsel, Sri S. Nagesh Reddy, argued that the FIR was filed belatedly, nearly two years after the alleged incident, and that the actions of the petitioner were part of official duties undertaken due to pandemic-related constraints. He contended that the engagement of M/s. Camsign was a collective APPSC decision and no criminal breach of trust could be alleged without prior sanction under Section 197 CrPC.
Relying on Delhi Race Club (1940) Ltd. v. State of Uttar Pradesh and Common Cause v. Union of India, counsel argued that ingredients of Sections 409 IPC (now under BNSS) were not made out, stating that the payment to M/s. Camsign was for services rendered and that official decisions were taken transparently.
The second petitioner’s counsel, Sri P.V.G. Umesh Chandra, asserted that his client had merely executed work as per a valid work order. He claimed no role in policy decisions, stating that the second petitioner, a private individual, acted strictly in execution of official instructions.
The learned Assistant Public Prosecutor, Sri A. Sai Rohit, submitted that 26 witnesses had been examined and that unqualified personnel were engaged for evaluating Group-I answer scripts. He maintained that both petitioners were uncooperative, gave evasive replies, and that release on bail at this stage could jeopardize the investigation. He further contended that sanction under Section 197 CrPC was not required during investigation.
The Court noted, "the allegations levelled against the petitioner calls for investigation which is at threshold stage." Addressing the nature of allegations, the Court recorded that the former Secretary of APPSC had engaged the services of a private firm and issued a cheque for Rs.1,14,32,312/- in that regard.
The Court stated, "The allegation against A-1 is that in his capacity as a Secretary of APPSC at the relevant point of time in the absence of a regular Chairman, has taken a decision to keep the answer scripts of Group-I main examinations for safe custody and evaluation of the same at the premises of M/s. Haailand Resorts."
It further noted, "The said complaint has been lodged to enquire into issue to find out as to what exactly was the service rendered by M/s. Camsign at the premises of M/s. Haailand Resorts under the instructions and supervision of the petitioner herein."
Referring to Section 409 IPC, the Court reiterated the legal position: "Whoever, being in any manner entrusted with property, or with any dominion over property in his capacity of a public servant... commits criminal breach of trust in respect of that property, shall be punished..."
Regarding sanction under Section 197 CrPC, the Court cited D.T. Veerupakshappa v. C. Subash, observing, "unless it is established that the alleged act was in excess of discharge of his official duties, and there is a reasonable connection between the act and the performance of official duty, the protection under Section 197 of the Cr.P.C., would not arise."
The Court recorded, "in the facts and circumstances of the present case, since the investigation is at the threshold, the protection as envisaged under Section 197 of Cr.P.C., would not enure to the benefit of the petitioner A-1."
Considering the bail principles, the Court stated, "the Court has to bear in mind the nature of allegations made against the accused, the punishment if convicted, and the character of the accused whether the presence of the Accused would be secured during the course of trial and is there a reasonable apprehension of witnesses being tampered."
The Court concluded, "Having regard to the nature of allegations made against the petitioners and since the investigation is at threshold stage, this Court does not deem it appropriate to enlarge the petitioners i.e., A-1 & A-2 in Cr. No.469 of 2024 on bail."
Regarding the first petitioner’s health, the Court noted, "the petitioner A-1 was however appears to have been discharged against medical advice since he was reluctant."
Accordingly, the Court held, "this Court grants liberty to the petitioner in Crl.P. No.5701 of 2025, A-1 to move an application before I Additional Judicial Magistrate of First Class, Vijayawada, seeking grant of medical bail for a limited period of two (2) weeks."
It further directed, "Upon filing of such an application, the learned Judge, after calling for report afresh on the medical condition of the petitioner, from the GGH, Vijayawada, is directed to dispose of the same as expeditiously as possible, not later than two (2) weeks, from the date of filing of the same, on such terms and conditions as it may deem fit and proper."
The Court finally disposed of the petitions as follows: "With the above observations, the Criminal Petition No.5701 of 2025 is disposed of and Criminal Petition No.5748 of 2025 is dismissed."
Advocates Representing the Parties:
For the Petitioners: S. Nagesh Reddy, Advocate for Petitioner/A-1; P.V.G. Umesh Chandra, Advocate for
For the Respondents: A. Sai Rohit, Assistant Public Prosecutor on behalf of Public Prosecutor
Case Title: Pendyala Sita Rama Anjaneyulu v. State of Andhra Pradesh; Pamidikalva Madhusudhan v. State of Andhra Pradesh
Neutral Citation: APHC010275932025
Case Number: Criminal Petition Nos. 5701 and 5748 of 2025
Bench: Justice Kiranmayee Mandava
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