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Manoj Goyal v. Rajasthan High Court & Ors.

Civil Appeal · 2026 INSC 699Decided 13 Jul 2026
C.A. No.-008142-008142 - 2018
Justice Sanjay Karol · Justice Prasanna B. Varale

Background

Manoj Goyal appeared for the 2011-2013 Rajasthan Additional District Judge recruitment under an amended rule requiring candidates to score at least 25% in the viva-voce interview. Despite ranking 11th out of 39 vacancies on aggregate marks, he was disqualified for scoring just half a mark short of the interview cut-off, even though some selected candidates had lower aggregate scores. He challenged the cut-off rule as unconstitutional and contrary to Shetty Commission recommendations (which the Supreme Court had earlier endorsed) that there be no interview cut-off; the Rajasthan High Court dismissed his challenge as academic since the rule was later deleted in 2017.

Decision Breakdown

The Supreme Court held that the Shetty Commission's recommendations were only guidelines, not binding directives that override a state's validly framed statutory recruitment rules, so the 25% interview cut-off was a legitimate exercise of rule-making power aimed at ensuring judicial officers possess essential qualities beyond written-exam knowledge. It also held Goyal was estopped from challenging the rules after participating in the selection process with full knowledge of them and only complaining after failing, and that disturbing a decade-old, fully implemented recruitment would unfairly disrupt the settled seniority of judges already appointed and open a "Pandora's box" of similar claims. The appeal was dismissed and the High Court's judgment affirmed.

Lesson Learnt

A candidate who takes part in a selection process under known rules, without objecting beforehand, generally cannot challenge those rules only after failing to get selected, and courts weigh the disruptive real-world consequences of unwinding long-settled appointments before granting relief.

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

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