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Education LawSupreme Court of India

Manilal vs The State of Rajasthan & Ors.

Not available · 2024 INSC 675Decided 10 Sept 2024
Not available

Background

Manilal applied for a Teacher Grade-III post under a 2017 Rajasthan recruitment advertisement. He had 44.58% marks in graduation but had taken admission to his B.Ed course in October 2009, before the National Council for Teacher Education's stricter minimum-marks requirement (50%, later reduced by later rules) came into force. His candidature was rejected for not meeting the 45% graduation cut-off, and his writ petition and writ appeal against this rejection were dismissed by the Rajasthan High Court, which relied on a different precedent (Dinesh Chandra Damor) involving a candidate who joined the B.Ed course much later, after the relevant cut-off date.

Decision Breakdown

The Supreme Court noted that a subsequent NCTE clarification (2019), issued following the Court's own earlier ruling in Neeraj Kumar Rai, exempted candidates who had taken B.Ed admission before 29 July 2011 from the minimum-marks requirement, and that in an on-point precedent (Ankul Singhal), the Rajasthan High Court itself had held it discriminatory under Article 14 to treat students admitted in the same academic session (2009-10) differently based merely on which round of counselling they joined. Manilal's case was materially identical to that of "Rakesh Gaur," a similarly-situated candidate who had already been granted relief by the High Court on this very reasoning: Manilal's admission (23.10.2009) even predated Gaur's. The Court held the Division Bench erred by instead applying the unrelated "Dinesh Chandra Damor" precedent (where the candidate joined over a year later, after the cut-off). It allowed the appeal, set aside the High Court's judgment, and directed that Manilal's earlier interim appointment be treated as a regular appointment with consequential benefits (though without back wages for the non-working period).

Lesson Learnt

Public authorities and courts cannot treat similarly-situated candidates from the same admission batch differently under the same recruitment rules. If one candidate in an identical position has already been granted relief, denying the same relief to another in materially the same facts violates the constitutional guarantee of equal treatment.

Manilal vs The State of Rajasthan & Ors. – Legal Case Shots | LegalAware