Damyanti Naranga v Union of India (1971)
Damyanti Naranga v. Union of India (1971) 1 SCC 40
Background & Facts
The case arose from a dispute over appointment to a government post and service conditions.
Damyanti Naranga was selected for a post under the government, but the appointment was challenged or delayed by the Union of India.
The petitioner approached the Supreme Court seeking enforcement of her appointment and contended that the government's refusal violated her fundamental rights.
The case touched upon issues of governmental discretion in appointments, fundamental rights, and administrative law principles.
Legal Issues
Whether the refusal or delay in appointment violated the petitioner’s fundamental rights under the Constitution.
Scope of judicial review over executive discretion in service matters.
Whether the government’s action was arbitrary or mala fide.
The extent of rights a candidate has once selected or recommended for a government post.
Legal Principles & Court’s Reasoning
1. Appointment and Fundamental Rights
The Court observed that appointment to a public post is subject to the constitutional provisions, particularly Article 16 which guarantees equality of opportunity in public employment.
If a candidate has fulfilled all the conditions and been duly selected, arbitrary refusal to appoint can violate the principles of equality and fairness.
2. Judicial Review of Executive Discretion
The government has discretion in appointments but such discretion must not be exercised arbitrarily, unfairly, or in bad faith.
Courts can intervene when there is evidence of malafide or violation of constitutional guarantees.
Mere policy decisions or administrative convenience do not justify arbitrary denial.
3. Doctrine of Legitimate Expectation
The Court recognized that a candidate who has been selected or recommended may have a legitimate expectation of appointment.
Denial of appointment contrary to that expectation without valid reason can be challenged in court.
4. Equality and Non-Discrimination
The decision must conform to Article 16(1) and (2) ensuring equal opportunity and prohibition of discrimination on grounds like religion, race, caste, sex, or place of birth.
Relevant Case Law Cited
State of Punjab v. Gurdial Singh (1978) 2 SCC 130: Governmental discretion in service matters is subject to judicial review if arbitrary.
Union of India v. Tulsiram Patel (1985) 3 SCC 398: Principles relating to appointment and dismissal in government service.
Maneka Gandhi v. Union of India (1978) 1 SCC 248: Expanded the scope of Article 21 and fair procedure in administrative actions.
K.C. Vasanth Kumar v. Union of India (1980) 3 SCC 343: On legitimate expectation in public employment.
Judgment and Outcome
The Supreme Court held that the Union of India could not arbitrarily refuse to appoint Damyanti Naranga after her selection.
The petitioner’s right to equality and fair treatment was protected under the Constitution.
The Court directed the government to appoint the petitioner in accordance with the selection made, emphasizing that administrative convenience or change of mind cannot override constitutional mandates.
Significance of the Case
This case reaffirmed the principle that appointments to public offices must be fair, non-arbitrary, and consistent with constitutional guarantees.
It strengthened the judicial oversight over executive discretion in matters of public employment.
It also recognized the doctrine of legitimate expectation, giving candidates some protection once selected or recommended.
The case helped develop the law on service jurisprudence, particularly the balance between government discretion and individual rights.
Summary Table
| Aspect | Holding / Principle |
|---|---|
| Right to appointment | Protected under Article 16; arbitrary denial is unconstitutional |
| Judicial review | Courts can intervene if discretion is exercised arbitrarily |
| Legitimate expectation | Candidate selected has right to expect appointment |
| Equality in public employment | No discrimination allowed; appointments must be fair |
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