Manoj Kumar vs. Union of India [February 20, 2024]
This Supreme Court case centered on the arbitrariness in the recruitment process for the post of primary school teacher. Manoj Kumar, the appellant, challenged the denial of marks for his Post Graduate (PG) degree during the selection process, arguing that the exclusion was arbitrary and unjust. The authorities had refused to award him additional marks for his PG qualification, claiming it was not in the relevant subject, which led to his non-selection. Both the Single Judge and Division Bench of the Delhi High Court dismissed his writ petition and appeal, invoking judicial restraint in academic matters.
Key Legal Issues
Whether the executive action in denying marks for additional qualifications was arbitrary and violated principles of fairness in public employment.
Whether courts can intervene in academic and administrative decisions relating to recruitment, especially when arbitrariness is alleged.
What remedies are available when the original relief (appointment) becomes unattainable due to the passage of time.
Supreme Court’s Analysis
The Court reaffirmed that while courts should exercise restraint in academic matters, they cannot allow arbitrary executive actions to go unaddressed. The Supreme Court held that the recruitment authority’s refusal to grant marks for the appellant’s PG degree, without any rational basis, was arbitrary and violated the principle of fairness in public employment.
The Court noted that clauses in the vacancy advertisement allowing flexibility in the selection process cannot be interpreted to grant unbridled discretion to the authorities to change or introduce new criteria arbitrarily.
Recognizing the significant delay in litigation and the closure of the concerned school, the Court acknowledged that reinstatement or appointment was no longer possible. However, it emphasized that courts must still address the injurious consequences of arbitrary and illegal actions by awarding reasonable restitution.
Judgment
The Supreme Court set aside the orders of the Single Judge and Division Bench of the Delhi High Court, declaring the action of the respondents as illegal and arbitrary.
As the original relief of appointment was no longer possible, the Court awarded monetary compensation of ₹1,00,000 to Manoj Kumar as an alternative restitutory measure, along with ₹25,000 as costs of proceedings.
The judgment reinforces the principle that constitutional courts must not dismiss writ petitions as futile merely because the original relief is unattainable; instead, they must fashion appropriate remedies to address the injustice caused by arbitrary state action.
Significance
This decision is a significant reaffirmation of judicial review over arbitrary executive actions in public employment. It clarifies that courts have a duty to ensure fairness and to provide alternative remedies, such as compensation, when reinstatement is not feasible. The ruling serves as a precedent for addressing the consequences of illegal or arbitrary administrative actions, thereby strengthening the rule of law in recruitment and service matters.
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