Delhi High Court Denies Bail to Rajneesh Kumar Pandey in Railway Employment Fraud Scam
In a significant judgment delivered on December 6, 2025, the High Court of Delhi has rejected a bail application filed by Rajneesh Kumar Pandey (also known as Satyendra Dubey) in connection with a massive railway employment fraud scheme. Justice Ajay Digpaul’s decision underscores the severity of financial crimes that exploit vulnerable job seekers by fraudulently impersonating government officials. The court distinguished the petitioner’s role as significantly more heinous than that of his co-accused, finding that the forging of official government documents and systematic deception warrant continued pre-trial custody.
Background of the Case and the Fraud Scheme
The case revolves around an elaborate fake employment scheme targeting unemployed candidates seeking positions in the Indian Railways. In FIR No. 170/2022 registered at the Police Station Economic Offences Wing, Mandir Marg, New Delhi, a 78-year-old ex-serviceman named Subbuswami lodged a formal complaint detailing how he and numerous job seekers were defrauded of a staggering sum of approximately ₹3.23 crore. The complainant alleged that he encountered a man named Sivaraman, who claimed to have close associations with various Members of Parliament and government ministers and offered to facilitate railway employment in exchange for monetary payments.
The modus operandi of the fraud scheme was meticulously planned and executed across multiple stages. Initially, when the complainant brought three job-seeking candidates, Sivaraman persistently demanded meetings, eventually introducing them to a person named Vikas Rana, who falsely represented himself as an IRIS officer and Deputy Director of Northern Railway at Connaught Place, Delhi. The victims were convinced to deposit substantial sums into bank accounts—₹33,20,000 was transferred by the initial batch of candidates during January-February 2022. Subsequently, 25 additional unemployed candidates approached the complainant seeking similar employment assistance, collectively paying ₹2,63,00,500 in so-called facilitation charges.
To lend credibility to their fraudulent scheme, the perpetrators subjected victims to what appeared to be formal onboarding procedures. Candidates underwent medical examinations at Railway Central Hospital, Connaught Place, and document verification at the Northern Railway office in Shankar Market. They were then taken to Baroda House to collect fabricated joining orders and training material. However, the actual “training” was a sham—candidates were merely asked to count trains passing a platform for a stipulated timeframe, after which they received bogus training completion certificates.
The Role of Rajneesh Kumar Pandey and Allegations Against Him
The court’s judgment reveals that Rajneesh Kumar Pandey emerged as the alleged mastermind responsible for forging the official documents used in the fraud. According to the status report dated 23.09.2024, Pandey was instrumental in creating forged appointment letters, joining letters, medical fitness certificates, and identity cards bearing the Northern Railway insignia. These documents were then handed over to unsuspecting candidates, creating the false impression that they had been officially appointed and would soon receive posting orders.
The financial trail of the conspiracy led directly to Pandey. The prosecution alleges that he received a cumulative sum of ₹80-90 lakhs via bank transfer and ₹1-1.15 crore in cash, in conspiracy with co-accused Sivaraman and Vikas Rana. When arrested on 05.04.2023 in Muzaffurpur, Bihar, investigators discovered ₹44 lakhs in cash deposits across various bank accounts belonging to Pandey. More significantly, a fake seal and forged documents were recovered from a rented accommodation allegedly used by Pandey. The Forensic Science Laboratory (FSL) report dated 14.06.2023 confirmed that “the sample seal of seized stamp are superimpose over the stamp pasted on all forge documents issued to the victims of the case”—providing crucial forensic evidence linking Pandey to the forgery operations.
Victim testimonies further implicated Pandey in the conspiracy. Several victims disclosed that the document verification process—a crucial step in their perceived onboarding—was conducted by Pandey himself, who introduced himself as an employee of the Indian Railways. This pattern of impersonation combined with document forgery established Pandey’s active participation in the fraud at multiple touchpoints.
The Bail Proceedings and Earlier Rejection
Pandey had initially approached the Additional Sessions Judge (ASJ) at the Special FTC (Fast Track Court), Patiala House Courts, seeking regular bail. The learned ASJ, in an order dated 30.07.2024, dismissed his bail application by noting the gravity of the allegations and the apparent “deeper roots” of the fake job syndicate, identifying Pandey as a main conspirator rather than a peripheral actor. The ASJ’s reasoning emphasized the large-scale nature of the economic offences, the difficulty in ascertaining the precise number of victims, and the presence of instruments and documents of forgery recovered from Pandey’s possession.
Pandey subsequently approached the High Court of Delhi with a fresh bail petition, advancing several arguments to secure his release. His senior counsel, Mr. Tanvir Ahmad Mir, argued that Pandey was actually a victim of the conspiracy perpetrated by Sivaraman and Rana, not a co-conspirator. Notably, the defense also raised the issue of parity, pointing out that co-accused Sivaraman had been granted bail by the Supreme Court on 21.02.2025, arguing that similar consideration should extend to Pandey.
Justice Digpaul’s Legal Analysis and Reasoning
Justice Ajay Digpaul approached the bail application by carefully examining each argument raised by the defense while relying on established principles of criminal law regarding bail jurisprudence. The court recognized that detailed scrutiny of evidence during bail hearings must be limited to avoid usurping the trial court’s power to eventually acquit or convict. As the judgment notes, following the Supreme Court’s guidance in cases such as Satish Jaggi v. State and State of Karnataka v. Sri Darhsan @ D.Boss, the court refrained from making definitive findings on the merit of allegations at the bail stage.
However, the court was satisfied that prima facie evidence existed against Pandey. The court observed that witness testimonies, recovery of forgery instruments, the forged documents themselves, and the FSL confirmation establishing that the recovered seal matched the fraudulent documents provided sufficient grounds for continued custody. The defense’s contentions that evidence was fabricated or that the recovery premises were not linkable to Pandey were deemed matters more appropriately determined during the trial.
Regarding the argument that Pandey was himself a victim, Justice Digpaul made a pointed observation, noting that “it is rather bold a statement,” thereby rejecting the defense’s primary narrative of innocence. The court found the allegation of financial transactions involving Pandey to be substantial—approximately ₹44 lakhs in cash deposits to accounts bearing his name during the period when the alleged crimes were committed.
Distinguishing the Petitioner’s Role from Co-Accused Sivaraman
A critical aspect of Justice Digpaul’s judgment involved the analysis of the parity argument. The defense had relied heavily on the Supreme Court’s decision granting bail to Sivaraman (dated 21.02.2025) to argue that Pandey was similarly deserving of bail. The court reproduced the Supreme Court’s order in its entirety, noting that Sivaraman’s bail was granted primarily on the basis that he was aged 68 years, suffered from significant heart ailments, and had already been incarcerated for over two years while the chargesheet had been filed back in March 2023.
However, Justice Digpaul drew a crucial distinction between the roles played by the two co-accused. Sivaraman’s primary function in the scheme was to lure victims and facilitate their meetings with co-conspirators, as well as to accept payments from them. In contrast, Pandey’s role involved the technical execution of forgery—creating counterfeit official documents bearing government seals and signatures. The court explicitly stated: “considering that, largely, the allegations against Sivaraman were that he lured the victims and facilitated their meeting with co-conspirators, as well as accepted payments from them, while the role attributable to the petitioner was that of the act of forgery of official government documents, right from training certificates to medical fitness certificates carrying the sanction of the Indian Railways, asides from allegations of impersonation of government officials, it is evident that the crimes alleged to be attributable to the petitioner are significantly more heinous than those allegations which have been levelled against co-accused Sivaraman”.
The court invoked the principle of parity established in Ramesh Bhavan Rathod v. Vishanbhai Hirabhai Makwana(Koli) and reiterated in Sagar v. State of U.P., which holds that a right to bail cannot accrue merely on the basis of a co-accused being released, absent careful consideration and comparison of the respective roles of each co-accused. This legal principle prevented Pandey from benefiting from Sivaraman’s bail, despite his arguments suggesting otherwise.
The Nature of the Crime and Its Societal Impact
Justice Digpaul’s judgment placed significant emphasis on the nature and gravity of the offences alleged against Pandey. The court recognized that financial crimes are “undoubtedly heinous, owing to their far-reaching consequences and the inability to accurately ascertain the precise number of victims effected”. This observation echoed the earlier reasoning of the ASJ that had dismissed Pandey’s first bail application.
The judgment highlighted an aggravating factor that elevated the seriousness of the crime: the fraudulent use of government sanction and official credentials. The court observed: “Buttressing this view, and acting as an acute aggravator of present circumstance, is the allegation that this large-scale financial crime has been committed by utilising the fraudulent sanction of the Government”. The court further emphasized the societal implications, noting that “the implications of the possible existence of a syndicate of this nature, operating with the fraudulent sanction of the Government to exploit vulnerable youth who are desperately in search for employment, is a crime that strikes at the very root of society’s conscience”.
This language reflects the court’s deep concern about not merely the economic loss suffered by victims, but the broader implications of governmental authority being fraudulently invoked to exploit vulnerable segments of society. Unemployment—particularly among educated youth—represents a significant social challenge, and crimes that exploit this vulnerability by falsely representing governmental processes strike at the institutional integrity upon which democratic governance depends.
Addressing the Incarceration Period Argument
The defense had argued that Pandey’s lengthy incarceration since May 2023—approximately 2.5 years by the time of the judgment in December 2025—should weigh heavily in favor of bail, operating as a “per se pass” for his release. Justice Digpaul addressed this argument by citing the Supreme Court’s judgment in Dipak Shubashchandra Mehta v. CBI, which establishes that lengthy incarceration alone is insufficient grounds for bail without consideration of other mitigating factors such as the accused’s ability to influence witnesses and hamper the trial.
The court found that the mitigating factors against Pandey’s release outweighed the aggravating factor of extended incarceration. Particularly relevant was the status of the trial at the pre-charge stage—meaning that the trial had not yet substantially progressed and the examination of witnesses lay ahead. The court expressed concern that “owing to the heinous nature of the offences alleged, the modus of the commission of the alleged crime, and the role attributed to the petitioner, this Court is not satisfied that the petitioner would abstain from influencing witnesses, considering that the trial is currently at a pre-charge stage”.
The Court’s Final Determination and Dismissal
After comprehensive consideration of all arguments, Justice Digpaul concluded that the petitioner had not made out a case for regular bail. The court found that the nature of the offences, the modus operandi of the crime, and the specific role attributed to Pandey—as the technical architect of the forgery scheme—warranted his continued incarceration pending trial. The petition was accordingly dismissed, along with any pending applications.
Implications and Broader Significance
This judgment carries significant implications for the criminal justice system’s treatment of financial crimes and fraud schemes. By refusing parity-based bail arguments and carefully distinguishing the roles of co-accused, the court has reinforced the principle that bail decisions must be individualized and based on specific circumstances. The decision also underscores the judiciary’s concern about crimes that exploit governmental authority and institutional frameworks to defraud citizens.
The judgment serves as a cautionary tale about the elaborate schemes employed by organized fraudsters to exploit job-seeking youth. The systematic nature of the scam—involving fake medical examinations, forged official documents, impersonation of government officials, and even bogus training programs—demonstrates the sophisticated level at which such crimes can operate. The court’s strong language regarding the threat to “society’s conscience” suggests a willingness by the judiciary to treat such offences with utmost severity.
Furthermore, the decision highlights the importance of forensic evidence in proving financial crimes. The FSL report confirming the match between the recovered seal and the forged documents played a crucial role in establishing Pandey’s guilt at the prima facie stage. This underscores the evidentiary value of scientific analysis in combating sophisticated fraud schemes.
The judgment also reflects the judiciary’s approach to the principle of parity in bail jurisprudence. By meticulously analyzing the differentiated roles of co-accused and refusing mechanical application of bail grants to other conspirators, the court has provided clear guidance that courts must engage in detailed comparative analysis rather than simply following precedent of another co-accused’s release.
