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Mamta Rohit v. Dr. Prafulla Ranjan & Ors.

Civil Appeal · 2018 INSC 892Decided 26 Sept 2018
Civil Appeal No. 15034 of 2017
Justice Kurian Joseph · Justice Sanjay Kishan Kaul

Background

The appellant was appointed Chief General Manager of the Pension Fund Regulatory and Development Authority (PFRDA) in 2011 after the appointing authority relaxed the usual qualification criteria in her favour; she resigned from her job at IDBI Bank to take up the post, was confirmed after probation, and received two annual increments. Unsuccessful rival candidates challenged her appointment before the Central Administrative Tribunal (CAT), and after a Finance Ministry show-cause notice, her appointment was cancelled in 2014. Although the Delhi High Court eventually set aside her appointment on the legal ground that there cannot be a "deemed relaxation" of eligibility without the appointing authority properly applying its mind, it granted no actual relief to the rival candidates who had challenged her.

Decision Breakdown

The Supreme Court agreed with the High Court's legal position that eligibility relaxation requires a proper, deliberate application of mind and cannot be presumed. However, it found this an "eminently fit case for doing complete justice between the parties" under its special equitable powers, noting the appellant had never misled anyone or concealed her qualifications, had resigned her prior job in reliance on the appointment, and had already served and been confirmed. Without treating the outcome as a precedent, the Court set aside the cancellation of her appointment and directed PFRDA to reinstate her forthwith, treating her service as continuous from her original appointment date (minus actual backwages for the interim period), while expressly limiting this relief to her individual case. A connected, separately filed special leave petition (Diary No. 4994/2018) was dismissed on the ground of a 240-day unexplained delay.

Lesson Learnt

Even where a legal technicality (such as an improperly granted relaxation) would otherwise invalidate an appointment, the Supreme Court can use its extraordinary equitable powers to protect an individual who acted in good faith and changed their position in reliance on the appointment, though such relief is case-specific and not meant to set a general precedent.

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

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