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Deependra Yadav and Others vs. State of Madhya Pradesh and Others

Not available · 2024 INSC 362Decided 1 May 2024
Not available
Justice C.T. Ravikumar · Justice Sanjay Kumar

Background

The Madhya Pradesh Public Service Commission (MPPSC) advertised 571 posts in 2019 and held a preliminary examination in January 2020 for over 3 lakh candidates. Midway through the process, the State amended a service rule governing how the merit list was prepared, changing how reserved-category candidates who qualified purely on merit were counted; this amended rule was applied to the ongoing recruitment before being reversed back to its original form in December 2021. This "lapse" triggered a string of litigation before the Madhya Pradesh High Court by both general and reserved-category candidates over which version of the rule should govern their selection.

Decision Breakdown

The Supreme Court traced the litigation history, including an earlier judgment (Kishor Choudhary) that had already directed the process be completed under the unamended 2015 Rules, and a later High Court ruling (Harshit Jain) that devised a special main examination for reserved-category candidates who became eligible once the preliminary results were revised. The Court held that this remedial process was legally sound and consistent with the settled principle that an "open" or unreserved merit list must include any candidate who qualifies on merit alone, regardless of their reservation category. Finding no fault in the Madhya Pradesh High Court's Division Bench judgment upholding this approach, the Supreme Court dismissed the civil appeal and the connected special leave petitions.

Lesson Learnt

When a government wrongly changes recruitment rules mid-process, courts will unwind the resulting unfairness by restoring the original rules and creating a fair mechanism (like a special supplementary exam) for candidates who were wrongly excluded, rather than letting a flawed rule change decide people's careers.

Official source (sci.gov.in)View Judgment (PDF)

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