A) ABSTRACT / HEADNOTE
This case examines the rejection of the appellant’s candidature for the post of Teacher Grade-III in the Tribal Sub-Plan (TSP) area due to inadequate graduation marks. The appellant, belonging to a reserved category, secured admission to a Bachelor of Education (B.Ed) program after a 2009 regulatory notification requiring 50% marks at the graduation level. However, subsequent legal developments exempted candidates admitted before July 29, 2011, from the minimum graduation percentage requirement. The court considered the principles of equal treatment and non-discrimination among similarly situated candidates and held that the appellant was entitled to regular appointment with consequential benefits but without back wages.
Keywords: Appointment, Teacher Grade-III, B.Ed Eligibility, Equal Treatment, Non-Discrimination.
B) CASE DETAILS
i) Judgment Cause Title:
Manilal v. The State of Rajasthan & Ors.
ii) Case Number:
Civil Appeal No. 10440 of 2024
iii) Judgment Date:
September 10, 2024
iv) Court:
Supreme Court of India
v) Quorum:
Justice B.R. Gavai and Justice K.V. Viswanathan
vi) Author:
Justice K.V. Viswanathan
vii) Citation:
[2024] 9 S.C.R. 218; 2024 INSC 675
viii) Legal Provisions Involved:
- Rajasthan Panchayati Raj Act, 1994
- Rajasthan Panchayati Raj Rules, 1996
- Notifications and Regulations issued by the National Council for Teacher Education (NCTE).
ix) Judgments overruled by the Case:
None specifically overruled but prior conflicting decisions were distinguished.
x) Case is Related to which Law Subjects:
Service Law, Administrative Law, Equality Before Law.
C) INTRODUCTION AND BACKGROUND OF JUDGMENT
The appellant challenged the rejection of his candidature for Teacher Grade-III in TSP areas, alleging discrimination in eligibility criteria enforcement. This dispute stems from varying interpretations of NCTE notifications on minimum qualifying marks for B.Ed admission. Conflicting rulings in similar cases necessitated Supreme Court intervention to establish clarity on eligibility and equality principles under Article 14 of the Constitution.
D) FACTS OF THE CASE
The appellant, a reserved category candidate, applied for the post of Teacher Grade-III in Rajasthan’s TSP area. Despite fulfilling the minimum 40% graduation mark requirement for B.Ed admission applicable to his category, his application was rejected for failing to secure 45% marks in graduation. Notably, he gained B.Ed admission in October 2009, after a notification requiring 50% marks for general candidates. Later, the NCTE clarified that the graduation mark criterion would not apply to candidates admitted before July 29, 2011.
Several similar cases, including Rakesh Gaur v. State of Rajasthan, received favorable rulings, but the appellant’s writ petition and subsequent appeals were dismissed. This discrepancy led to the present appeal.
E) LEGAL ISSUES RAISED
i) Whether the appellant, who secured less than 45% marks in graduation but was admitted to the B.Ed course in 2009, met the eligibility criteria?
ii) Whether denying the appellant’s appointment violated Article 14 of the Constitution, given that similarly situated candidates received relief?
iii) Whether the retrospective application of the NCTE’s clarification impacted the appellant’s claim?
F) PETITIONER/APPELLANT’S ARGUMENTS
i) The appellant argued that he fulfilled the B.Ed admission criteria for reserved categories at the time of his enrollment in 2009. The rejection of his candidature based on subsequent rules violated the doctrine of legitimate expectation.
ii) He emphasized the principle of equal treatment, pointing out that similarly situated candidates, such as Rakesh Gaur, were granted relief. Discrimination within a homogeneous group of candidates, admitted during the same academic session, was arbitrary and unconstitutional.
iii) The NCTE’s notification of November 2019 clarified that the minimum graduation percentage requirement did not apply to candidates admitted before July 29, 2011. This clarification supported the appellant’s case.
G) RESPONDENT’S ARGUMENTS
i) The respondents maintained that the appellant failed to meet the 45% graduation mark criterion required under the 2009 notification. His admission to the B.Ed course was inconsequential for determining eligibility for the advertised post.
ii) They argued that the decisions in other cases, such as Rakesh Gaur, could not be universally applied as precedents due to factual variances.
iii) The retrospective applicability of the NCTE clarification, they contended, could not override the recruitment rules in force during the appellant’s application.
H) RELATED LEGAL PROVISIONS
i) Article 14, Constitution of India – Right to Equality
ii) Rajasthan Panchayati Raj Act, 1994
iii) Rajasthan Panchayati Raj Rules, 1996
iv) NCTE Notifications dated August 23, 2010, and July 29, 2011
I) JUDGMENT
a. Ratio Decidendi
The Supreme Court ruled that the appellant could not be discriminated against within a homogenous group of candidates admitted during the same academic session. The court emphasized that inconsistent treatment of identically placed individuals violated Article 14. The NCTE clarification provided retrospective protection to the appellant.
b. Obiter Dicta
The court noted the importance of uniformity and fairness in applying recruitment rules to avoid arbitrary exclusions.
c. Guidelines
- The appellant’s appointment must be treated as regular.
- He is entitled to consequential benefits, excluding back wages.
- Fitment of pay should be ensured.
- Authorities must issue compliance orders within four weeks.
J) CONCLUSION & COMMENTS
This judgment underscores the judiciary’s commitment to upholding equality and fairness in service law. By aligning administrative decisions with constitutional principles, it reinforces the doctrine of equal treatment under Article 14.
K) REFERENCES
a. Important Cases Referred
- Rakesh Gaur v. State of Rajasthan
- Neeraj Kumar Rai v. State of Uttar Pradesh
- Ankul Singhal v. State of Rajasthan
b. Important Statutes Referred
- Rajasthan Panchayati Raj Act, 1994
- Rajasthan Panchayati Raj Rules, 1996
- NCTE Notifications (2009, 2010, and 2011)
