Dr. (Major) Meeta Sahai v. State of Bihar & Ors.
Background
The appellant, a doctor who had worked at an Army Hospital, applied for the post of General Medical Officer in Bihar's state health service. Under the applicable recruitment rules, candidates could earn extra marks ("weightage") for prior work experience, but the authorities refused to count her Army Hospital service because Rule 6(iii) of the Bihar Health Service Rules, 2013 was read to cover only hospitals run directly by the Bihar Government. The Patna High Court upheld this narrow reading, and she appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that interpreting "Government hospitals" to mean only hospitals run by the State of Bihar itself, excluding hospitals run by the Central Government, Panchayats, Municipalities, or other public authorities, was arbitrary and anti-merit, and would violate the constitutional guarantee of equal treatment. The Court reasoned that the rule's real purpose was to recognize experience in non-private hospitals serving similar challenging conditions, not to discriminate based on which government ran the hospital. It therefore construed Rules 5 and 6(iii) to include experience gained at any non-private hospital, government or quasi-government, within Bihar. The appeal was allowed, and the authorities were directed to prepare a fresh merit list giving the appellant and similarly placed candidates due weightage within two months.
Lesson Learnt
When a government recruitment rule is ambiguous, it must be interpreted in line with its underlying purpose and constitutional equality principles, not read narrowly in a way that arbitrarily excludes similarly situated candidates from fair consideration.