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Education LawSupreme Court of India

Parimal Kumar v. The State of Jharkhand

Civil Appeal · 2025 INSC 134Decided 30 Jan 2025
C.A. No.-001297-001297 - 2025 (with connected appeal, Gurucharan Mahto v. State of Jharkhand)
Justice J.K. Maheshwari · Justice Rajesh Bindal

Background

Jharkhand had not conducted its own Teacher Eligibility Test (JTET) since 2016, leaving many aspirants unable to qualify under the state's own rules. When the state finally advertised Assistant Teacher posts in 2023, candidates who had instead cleared the Central TET (CTET) or another state's TET went to the Jharkhand High Court, which allowed them to also compete in the ongoing recruitment. JTET-qualified candidates, who alone met the state's 2022 Recruitment Rules at the time the process began, challenged that High Court order before the Supreme Court.

Decision Breakdown

The Supreme Court held that allowing CTET/other-state-TET holders into a recruitment process that was already underway effectively changed the eligibility criteria mid-stream, which is impermissible unless there is wide publicity and a fair fresh opportunity for all similarly situated candidates: a principle drawn from the Constitution Bench ruling in Tej Prakash Pathak. It also found the State's own Advocate General had made a concession before the High Court that contradicted the State Government's actual stance, calling this "unconscionable, unjustified and unfair." The High Court's judgment was set aside; only candidates who held the necessary JTET qualification under the pre-amendment 2022 Rules are eligible for the ongoing 2023 recruitment, with appointments to be made strictly on merit.

Lesson Learnt

Once a public recruitment process begins under a defined set of eligibility rules, the goalposts cannot be moved partway through to admit a new category of candidates without giving everyone else fair notice and an equal chance to compete: consistency in the "rules of the game" is a basic fairness requirement in government hiring.

Parimal Kumar v. The State of Jharkhand – Legal Case Shots | LegalAware