Mahesh Chand Bareth & Anr. vs The State of Rajasthan & Ors.
Background
This was a lead judgment disposing of a batch of 47 connected appeals arising from recruitment to the post of "Prabodhak" (a teaching/literacy-related post) in Rajasthan. The State had issued guidelines in May 2008, before the recruitment advertisement, granting age relaxation and extra "bonus marks" in the interview to candidates who had prior experience working under certain government literacy/education projects (where they were paid an honorarium). Candidates who were regular teachers in recognised schools but lacked this project experience challenged the scheme as discriminatory, arguing it unfairly favoured project-experience candidates in both age limits and bonus marks.
Decision Breakdown
The Supreme Court framed two questions: whether the age relaxation for project-experience candidates violated Article 14, and whether awarding them extra bonus marks was discriminatory or beyond the rules. The Court held that the State had a legitimate, rational basis for the differential treatment: given Rajasthan's particular problems of teacher absenteeism and student dropout rates, the State had run special projects to address these issues, and rewarding that specific project experience served a real public purpose. Since the guidelines fixing the bonus-marks scheme were framed and made known before the advertisement was issued, and were applied uniformly to all applicants, there was no unfairness or "changing rules after the game began." The Court found no illegality in either the age relaxation or the bonus marks and dismissed all the appeals.
Lesson Learnt
A government recruitment scheme that treats different classes of candidates differently (such as extra marks or age relaxation for particular experience) does not automatically violate the constitutional guarantee of equality, so long as the differentiation is based on a rational, transparent policy that existed before the process began and is applied consistently to everyone in that class.