Managing Director, M.P. State Agricultural Marketing Board and Ors. vs. Harpal Singh and Ors.
Background
Harpal Singh's father, a peon in the Krishi Upaj Mandi Samiti, Alampur (Madhya Pradesh), died in harness in February 2019. Following the state's compassionate appointment policy, Harpal Singh was appointed to a Class-III post (Assistant Grade-III) in September 2020, conditional on clearing a Computer Proficiency Certification Test (CPCT) within three years. He was unable to clear the test, and the authorities sought to deny him any appointment on that ground. The Madhya Pradesh High Court's Single Bench (later upheld by a Division Bench) had directed the authorities to sympathetically consider appointing him to a lower Class-IV post instead, and the Marketing Board appealed against this to the Supreme Court.
Decision Breakdown
The Supreme Court dismissed the Board's appeal and upheld the High Court's direction. It held that compassionate appointment schemes exist to address the exceptional hardship caused by an employee's death in service, and that procedural conditions like the CPCT requirement should not be applied so rigidly as to deny all relief to a dependent who could not meet a Class-III qualification, when a Class-IV post remained available. The Court emphasised that justice should not be sacrificed to technicality, and that since compassionate appointments are made against posts specifically earmarked for that purpose (not against general recruitment vacancies), granting relief here does not violate the equality guarantees under Articles 14 and 16. It directed the authorities to consider Harpal Singh's case for compassionate appointment to a Class-IV post within six weeks.
Lesson Learnt
Compassionate appointment schemes must be interpreted humanely and purposively: a dependent's failure to meet a qualifying condition for a higher post should not automatically shut the door on being considered for a lower, still-available post, since the scheme's purpose is to provide timely relief to families left without support.