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Dr. Thingujam Achouba Singh & Ors. v. Dr. H. Nabachandra Singh & Ors.

Civil Appeal · 2020 INSC 342Decided 17 Apr 2020
Civil Appeal Nos. 2250-2252 of 2020
Justice R. Banumathi · Justice R. Subhash Reddy

Background

The Regional Institute of Medical Sciences (RIMS), Imphal, a major public hospital in the north-east, needed to fill the vacant post of Director. After an initial advertisement with a 62-year age cap drew objections, the age of superannuation was raised to 65 and a fresh advertisement was issued in 2016. Several aggrieved doctors challenged this advertisement before the Manipur High Court, which went further than what was asked and struck down the underlying recruitment rules themselves, directing reconsideration of age and qualification relaxations.

Decision Breakdown

The Supreme Court held that the High Court had exceeded its mandate: none of the three writ petitions had actually challenged the validity of the recruitment rules, only the advertisement, yet the High Court invalidated the rules on its own initiative. The Court found no requirement in RIMS's own bye-laws that amended rules be separately notified to the public, and held that the experience criteria in the advertisement were consistent with Medical Council of India regulations once RIMS was correctly treated as an affiliated teaching hospital. It also held that a court cannot direct an employer to grant an age or qualification relaxation that was never offered in the advertisement, since eligibility criteria are the employer's prerogative. The appeals were allowed and the High Court's common judgment was set aside.

Lesson Learnt

Courts will not go beyond the specific relief sought by petitioners, and no candidate can claim a relaxation in eligibility criteria as a matter of right if it was never offered in the recruitment advertisement.

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

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