Leelavathi N. & Ors. vs. The State of Karnataka & Ors.
Background
Following a 2022 Karnataka government recruitment notification for 15,000 Graduate Primary Teacher posts, a provisional select list published in November 2022 excluded certain married female OBC candidates because they had submitted caste-and-income certificates in their father's name rather than their husband's. Some affected candidates challenged the exclusion before the Karnataka High Court, while others were directed by a different bench of the same High Court to approach the Karnataka State Administrative Tribunal (KSAT) instead. A Single Judge of the High Court entertained one such writ petition and ruled on the merits, but a Division Bench later set that aside, holding the writ petitions not maintainable and relegating the matter to the KSAT, prompting this batch of cross-appeals to the Supreme Court.
Decision Breakdown
The Supreme Court examined the statutory powers of the KSAT under the Administrative Tribunals Act, 1985 and found it fully equipped (through its rules on procedure, contempt, and review) to effectively and holistically adjudicate the recruitment dispute, so the Division Bench was right to hold the writ petitions not maintainable and to send the matter to the KSAT instead. The Court also rejected the plea to revive the original provisional select list, noting that a mere provisional list confers no vested right on candidates named in it and reviving it would create confusion. The entire batch of appeals was accordingly dismissed, with earlier interim directions of the Supreme Court made absolute and 500 reserved posts to be filled strictly per the KSAT's eventual final judgment; the Court expressly confined itself to the maintainability question and did not decide the underlying merits.
Lesson Learnt
Where a specialised tribunal like a State Administrative Tribunal has full statutory power to adjudicate a service dispute, courts will insist that aggrieved candidates go through that tribunal rather than the writ court; and being on a merely provisional (not final) select list does not by itself create an enforceable right to a post.