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Legal Case Shots

Court judgements broken down into the case type, how the decision played out, and the lesson worth remembering, with the full judgement available as a PDF.

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Service & Administrative LawSupreme Court of India

Durgapur Steel Plant & Ors. v. Bidhan Chandra Chowdhury & Ors.

Civil Appeal · 2026 INSC 459Decided 7 May 2026
C.A. No.-007073-007073 - 2026 (arising from SLP (Civil) No. 41 of 2020)
Justice Pamidighantam Sri Narasimha · Justice Alok Aradhe

Background

Durgapur Steel Plant (a unit of Steel Authority of India) advertised 200 posts of Plant Attendant in 2007-08; over 29,000 candidates sat the written exam, of whom 1,530 qualified, and 194 were eventually appointed. The respondents, who were not among those appointed, filed a case seeking disclosure of exam results and marks and sought to stop further appointments, without themselves asking to be appointed. The Central Administrative Tribunal and later the Calcutta High Court ruled in the respondents' favour, directing the company to appoint them, reasoning that the company had failed to produce or preserve the examination records and could not prove the respondents had failed. The company appealed to the Supreme Court.

Decision Breakdown

The Supreme Court set aside the directions to appoint the respondents. It held that neither the recruitment rules nor the advertisement required publishing every candidate's marks, that there was no rule mandating indefinite preservation of exam records, and that the company's explanation for non-availability of old records was bona fide. Critically, the Court noted the respondents had never actually claimed to have passed the exam or sought their own appointment in the original petitions: merely showing they hadn't been proven to have "failed" was not enough to establish they had "passed." The Court also noted that a place on a select list does not create an indefeasible right to appointment, and that the qualification criteria had since been revised, making retrospective appointment impractical after nearly two decades. However, recognising that one respondent had pursued the litigation in good faith since 2008, the Court directed the company to pay him Rs. 5,00,000 as compensation instead of ordering appointment.

Lesson Learnt

In recruitment litigation, a candidate must affirmatively show they cleared the selection process to claim appointment: the mere absence of proof that they failed, or the employer's inability to produce decades-old records, is not sufficient; courts may still award monetary compensation for a flawed process even while declining to order appointment.

Durgapur Steel Plant & Ors. v. Bidhan Chandra Chowdhury & Ors. – Legal Case Shots | LegalAware