Dr. Professor Rajendra Chaudhary and Anr. v. The State of Uttar Pradesh and Ors.
Background
After 12 years without any direct recruitment to Professor posts in Uttar Pradesh's government medical colleges, the state advertised 47 vacancies in 2015 without reserving any posts for Scheduled Castes, Scheduled Tribes, or Other Backward Classes, and raised the maximum recruitment age from 45 to 65 years. Candidates challenged both the lack of reservation and the age increase in the Allahabad High Court, which dismissed their petition. They then appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that reservation under the Uttar Pradesh Reservation Act must be calculated department/specialty-wise (as a single unit) rather than across the entire cadre of Professors, and since each department had fewer than five posts available for direct recruitment, the reservation rules governing a minimum cadre size were correctly held inapplicable. On the age limit, the Court found that Medical Council of India regulations (which permitted up to 70 years) override the State's own Service Rules (which capped it at 45), so the government's order raising the limit to 65 to address a chronic shortage of qualified teaching staff was valid and did not need to be separately challenged as it only supplemented, not replaced, the rules. The Court also noted the unchallenged government order from 2015 could not now be questioned indirectly through this appeal. Both appeals were dismissed, and the State was directed to expedite filling the posts.
Lesson Learnt
Reservation and eligibility requirements set by statute can operate differently depending on how a "unit" (such as a department versus an entire cadre) is defined in the governing rules, and specialized regulatory body rules (like the Medical Council of India's) can override conflicting state service rules on matters within that body's domain.