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Dr. Manoj Kumar Rawat v. State of UP & Ors.

Civil Appeal · 2026 INSC 508Decided 19 May 2026
C.A. No.-007996-007996 - 2026
Justice J.K. Maheshwari · Justice Atul S. Chandurkar

Background

The appellant was a waitlisted candidate for the post of Principal in a Government-Aided College in Uttar Pradesh under the old 1980 Act. After a new selection Act came into force in 2023 repealing the old one, State authorities nonetheless issued fresh orders in late 2023/early 2024 recommending and posting the appellant as Principal of Meerut College, relying on the old waitlist. The sitting Officiating Principal of Meerut College challenged these orders in the Allahabad High Court, which quashed them; a Division Bench upheld that decision, prompting this appeal to the Supreme Court.

Decision Breakdown

The Supreme Court held that once the new Act repealed the old one, the old waitlist/panel automatically lapsed, and authorities were bound to follow the fresh appointment procedure under the new Act rather than resurrecting the old list. It found that the only "act done" under the old Act before repeal was the original 2022 recommendation (which had already been superseded by the appellant's own request and the Director's clear refusal to change his posting), so there was no valid basis for the December 2023 and January 2024 orders placing him at Meerut College. The Court also held that the Officiating Principal had locus standi to challenge the appointment, following its earlier precedent, and it criticised State officers for supporting an unlawful stand before the courts. The appeal was dismissed, with each side bearing its own costs.

Lesson Learnt

When a governing statute is repealed and replaced, benefits, waitlists, or recommendations validly available only under the old law do not survive automatically unless the new law's savings clause specifically preserves them: public authorities cannot revive lapsed processes under the repealed law after the new statute takes effect.

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

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