Mahesh Chand Bareth & Anr. vs. State of Rajasthan & Ors. [July 08, 2024]
Citation: [2024] 7 S.C.R. 196; 2024 INSC 466; 2024 LiveLaw (SC) 442
Background and Issues
This Supreme Court case centered on the constitutional validity of Rule 13(v) of the Rajasthan Panchayati Raj Prabodhak Service Rules, 2008, which provided age relaxation and bonus marks to candidates with prior service in government educational projects (such as Shiksha Karmi and Rajiv Gandhi Pathshala) when applying for the post of Prabodhak (teacher). The petitioners challenged these provisions, arguing they violated Article 14 of the Constitution by discriminating against other candidates and unfairly favoring project-employed applicants.
Facts
The Rajasthan government had implemented educational projects to address chronic absenteeism among teachers and high dropout rates in rural schools.
Local youth were engaged as para-teachers under these projects, often working in challenging conditions and receiving only honorarium.
When regular recruitment for Prabodhak posts was initiated in 2008, Rule 13(v) allowed age relaxation for project-employed candidates who were within the age limit at their initial engagement but had since crossed the threshold.
Bonus marks were also awarded to candidates with project experience.
The petitioners, unsuccessful in the recruitment, argued that these provisions were arbitrary and discriminatory, lacking a rational nexus to the objective of quality education.
Arguments
Petitioners:
Claimed Rule 13(v) and the bonus marks system created an unfair advantage for project-experienced candidates, violating the equality principle under Article 14.
Argued that the selection process lacked transparency and that the rules were changed after the process began.
State of Rajasthan:
Defended the provisions as a legitimate policy decision to recognize the contributions of para-teachers who served in difficult rural conditions.
Emphasized the historical context and the need to incentivize and retain experienced educators in underserved areas.
Supreme Court’s Findings and Rationale
The Court upheld the constitutional validity of Rule 13(v), finding that the classification of project-employed candidates for age relaxation and bonus marks was based on an intelligible differentia with a rational nexus to the objective of improving rural education.
The Court observed that para-teachers played a crucial role in addressing absenteeism and motivating children in remote areas, justifying their preferential treatment.
It rejected the argument that the guidelines were not in the public domain or that the rules were changed mid-process, noting that all relevant guidelines were issued before the recruitment advertisement and applied uniformly.
The Court reaffirmed that policy decisions on age relaxation and bonus marks fall within the executive’s domain and should not be interfered with unless manifestly arbitrary or discriminatory.
The appeals were dismissed, and the recruitment process, including the award of age relaxation and bonus marks, was upheld.
Key Takeaways
Rule 13(v) is constitutionally valid: Age relaxation and bonus marks for project-experienced candidates are neither arbitrary nor discriminatory.
Legitimate classification: The differential treatment is justified by the unique contributions and hardships faced by para-teachers in rural educational projects.
Policy domain: Courts will not interfere with executive policy unless it is palpably unreasonable or discriminatory.
Recruitment process upheld: The process was transparent, guidelines were pre-published, and no prejudice was caused to other candidates.
This judgment reinforces the principle that reasonable classification based on relevant experience and service in public interest projects can withstand constitutional scrutiny under Article 14.
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