Narender Singh vs. The State of Haryana & Ors.
Background
Narender Singh, a serving government JBT teacher, applied for the post of Assistant Professor (History) with the Haryana Public Service Commission and needed a "No Objection Certificate" (NOC) from his employer, the District Elementary Education Officer, which he applied for well before the deadline in March 2016. Despite repeated reminders, the NOC was not issued for over two years, forcing him to approach the High Court; he was allowed to interview provisionally with his result kept sealed, but the Commission went ahead and appointed other candidates in July 2018 without him, even though his NOC arrived (and was submitted) before the appointments were finalised. The High Court's Single Judge and Division Bench both dismissed his petitions, holding he had approached the court too late, though the Single Judge fined the employer Rs. 50,000 for the delay in issuing the NOC.
Decision Breakdown
The Supreme Court held that on a careful review of the timeline, there was no delay or fault whatsoever on Narender Singh's part: every delay was caused by his own government employer's failure to promptly issue the NOC, a fact even the High Court had implicitly recognized by penalising the employer. It found it undisputed that Singh had scored higher marks than the last selected candidate, making him more meritorious, and held that denying him appointment for a lapse that was not his fault was unjustifiable. Exercising its special power under Article 142 of the Constitution to do complete justice, the Court balanced fairness to Singh against the settled reliance interests of the candidate who had already been serving in the post since 2018, directing that Singh be appointed as Assistant Professor without back wages (applying "no work no pay"), while separately directing the state to accommodate the incumbent respondent on another vacant post rather than displacing him.
Lesson Learnt
A candidate who is otherwise more meritorious cannot be denied a government appointment for delay or paperwork failures caused entirely by the employer's own inaction; where displacing an innocent incumbent would cause serious hardship, courts can use their equitable powers to grant relief to the wronged candidate while protecting the incumbent through alternative accommodation, rather than an all-or-nothing outcome.