A) ABSTRACT / HEADNOTE

This case examines the constitutional validity of Rule 13(v) of the Rajasthan Panchayati Raj Prabodhak Service Rules, 2008, which provides age relaxation for candidates previously employed under government educational projects. The petitioners contested the bonus marks allocation for such candidates during recruitment for Prabodhak posts, arguing that it violated Article 14 of the Constitution by being discriminatory. The Court, emphasizing the importance of project workers’ contributions to rural education, upheld the provisions, reasoning that the differential treatment was based on a valid classification with a rational nexus to the objective of promoting quality education in underserved areas.

Keywords

1. Rajasthan Panchayati Raj Prabodhak Service Rules, 2008
2. Age relaxation
3. Article 14
4. Bonus marks
5. Project employed applicants

B) CASE DETAILS

i) Judgment Cause Title:
Mahesh Chand Bareth & Anr. v. State of Rajasthan & Ors.

ii) Case Number:
Civil Appeal No. 7906 of 2010

iii) Judgment Date:
July 8, 2024

iv) Court:
Supreme Court of India

v) Quorum:
Justices Surya Kant and K.V. Viswanathan

vi) Author:
Justice K.V. Viswanathan

vii) Citation:
[2024] 7 S.C.R. 196 : 2024 INSC 466

viii) Legal Provisions Involved:

• Article 14, Constitution of India
• Rajasthan Panchayati Raj Act, 1994
• Rajasthan Panchayati Raj Prabodhak Service Rules, 2008

ix) Judgments overruled by the Case (if any):
None.

x) Case is Related to which Law Subjects:
Constitutional Law, Service Law, Education Law

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The case centers on recruitment for the post of Prabodhak (Teacher) under the Rajasthan Panchayati Raj Prabodhak Service Rules, 2008. The petitioners contended that the Rules provided unjust benefits to candidates with prior project experience. The State defended these provisions, citing the unique role of para-teachers in advancing rural education, particularly in underserved areas. The appeal stems from the Rajasthan High Court’s decision, which upheld the validity of the Rules.

D) FACTS OF THE CASE

1. The Rajasthan government introduced educational projects like Rajiv Gandhi Pathshala and Shiksha Karmi Project to address the challenges of absenteeism and dropouts in rural schools.
2. These projects involved engaging local youth as para-teachers, who were later considered for recruitment as Prabodhaks under special rules.
3. Rule 13(v) granted age relaxation to project-employed applicants who were within the age limit when initially appointed but had since exceeded the age threshold.
4. The recruitment process also awarded bonus marks to candidates with project experience.
5. Petitioners, regular teachers in recognized institutions, challenged the rules for being discriminatory and arbitrary under Article 14 of the Constitution.

E) LEGAL ISSUES RAISED

1. Validity of Rule 13(v): Whether granting age relaxation to project-employed applicants violates Article 14.
2. Bonus Marks Allocation: Whether awarding additional marks to project-employed candidates was discriminatory and ultra vires the Rules.

F) PETITIONER/APPELLANT’S ARGUMENTS

1. Discrimination under Article 14:
   Petitioners argued that granting age relaxation only to project-employed candidates unfairly excluded others with similar teaching experience.

2. Ultra Vires Guidelines:
   The allocation of bonus marks through executive guidelines was claimed to be beyond the Rules’ framework and not included in the advertisement.

3. Change in “Rules of the Game”:
   Petitioners alleged that introducing bonus marks after the advertisement altered the criteria mid-process, violating established principles (relying on Bedanga Talukdar v. Saifudaullah Khan, (2011) 12 SCC 85).

G) RESPONDENT’S ARGUMENTS

1. Historical Context:
   The State justified the Rules by highlighting the critical role of para-teachers in rural education, particularly in areas with absenteeism and high dropout rates.

2. Rational Classification:
   The State contended that project-employed candidates formed a separate, validly classified group due to their unique challenges and contributions.

3. Policy Discretion:
   The State argued that decisions regarding age relaxation and bonus marks were policy matters and fell within executive discretion, as upheld in Union of India v. Shivbachan Rai, (2001) 9 SCC 356.

H) JUDGMENT

a. Ratio Decidendi

1. Rule 13(v):
   The Court upheld the age relaxation provision, stating it was based on a valid classification. Para-teachers had acquired relevant skills under challenging conditions, warranting preferential treatment.

2. Bonus Marks:
   The Court found no illegality in awarding extra marks, emphasizing that it aligned with the objective of retaining experienced candidates for rural education.

b. Obiter Dicta
Courts must refrain from interfering in policy decisions unless they are palpably arbitrary or discriminatory.

c. Guidelines Issued
The executive guidelines supplementing the Rules were not ultra vires. The Court emphasized that they provided clarity without altering the Rules’ core structure.

I) CONCLUSION & COMMENTS

The Court’s decision reinforces the principle that differential treatment based on intelligible criteria is permissible under Article 14. It underscores the need to recognize and reward contributions in specialized contexts like rural education, balancing equity with merit.

J) REFERENCES

a. Important Cases Referred

1. Union of India v. Shivbachan Rai, (2001) 9 SCC 356
2. Bedanga Talukdar v. Saifudaullah Khan, (2011) 12 SCC 85
3. Satya Dev Bhagaur v. State of Rajasthan, (2022) 5 SCC 314
4. Raj Kumar v. State of Maharashtra, (1982) 3 SCC 313
5. Kailash Chand Sharma v. State of Rajasthan, (2002) 6 SCC 562

b. Important Statutes Referred

1. Article 14, Constitution of India
2. Rajasthan Panchayati Raj Prabodhak Service Rules, 2008
3. Rajasthan Panchayati Raj Act, 1994