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Constitutional LawSupreme Court of India

Satya Dev Bhagaur & Ors. vs The State of Rajasthan and Ors.

Civil AppealDecided 17 Feb 2022
Civil Appeal No. 1422 of 2022
L. Nageswara Rao · B.R. Gavai

Background

Rajasthan's recruitment rules for the post of Nurse Compounder Junior Grade gave "bonus marks" to candidates who had prior contractual work experience under government health schemes such as the National Health Mission (NHM) and National Rural Health Mission (NRHM). A group of candidates who had done similar NHM/NRHM work in other states, not Rajasthan, asked the Rajasthan High Court to direct the state to count their out-of-state experience too. A single judge ruled in their favour, but a Division Bench of the High Court reversed this, holding the bonus was meant only for experience gained within Rajasthan; several batches of similarly placed candidates lost on the same point and all appealed together to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the High Court's Division Bench view and dismissed all the appeals. It held that courts should be slow to interfere with policy choices unless they are shown to be arbitrary or lacking any rational basis, and that Rajasthan's decision to reward only in-state NHM/NRHM experience was rationally linked to a real difference: the state's own training programs are tailored to its specific rural, tribal and arid-zone conditions, giving in-state workers genuinely different (and directly relevant) experience compared to workers from elsewhere. Since the recruitment advertisement's list of authorities competent to certify such experience was itself confined to Rajasthan-based officials, the rules were never intended to cover out-of-state service, and the distinction did not amount to unconstitutional discrimination.

Lesson Learnt

A government recruitment policy that gives extra credit for specific local work experience is not automatically discriminatory under Article 14, as long as the state can show a genuine, reasoned difference between in-state and out-of-state experience relevant to the job, courts will not strike down or expand such an eligibility scheme.

Satya Dev Bhagaur & Ors. vs The State of Rajasthan and Ors. – Legal Case Shots | LegalAware