Dinesh Kumar Gupta & Anr. v. The Hon'ble High Court for Judicature of Rajasthan & Ors.

Miscellaneous Application · 2021 INSC 803Decided 30 Nov 2021
Miscellaneous Application Nos. 1729-1736 of 2021
Justice Uday Umesh Lalit · Justice Vineet Saran

Background

The dispute concerned the seniority of judicial officers in Rajasthan: specifically, whether 47 judicial officers promoted in 2010 and officers directly recruited (or appointed through a Limited Competitive Examination) in 2013 belonged to the "same selection process" for seniority purposes. The Supreme Court had earlier ruled against treating them as part of one selection process, relying on its decision in K. Meghachandra Singh (which had overruled an earlier precedent, N.R. Parmar). The petitioners sought review of that judgment, also pointing to what they said was a factual error in one paragraph of it.

Decision Breakdown

The Court held that none of the grounds raised disclosed any error apparent on the record justifying interference, reaffirming that officers who entered the cadre more than three years before the direct recruits/LCE candidates were rightly treated as senior to them. It did acknowledge a minor typographical error (an incorrect date in one paragraph) and directed the Registry to issue a corrigendum correcting it, but dismissed the review petitions themselves and made no order on the connected miscellaneous applications.

Lesson Learnt

Even when a minor factual slip is found in a judgment, the Court will usually correct it by a corrigendum rather than reopen the whole decision through review, so long as the slip does not affect the core reasoning or outcome.

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