R. Muthukumar & Ors. vs. The Chairman and Managing Director TANGEDCO & Ors.
Background
TANGEDCO (Tamil Nadu's power distribution utility) advertised 4000 ITI Helper (Trainee) posts in 2012 and selected candidates through a written test and interview. Some unsuccessful candidates challenged the process in the Madras High Court; while their case was pending, TANGEDCO and a group of 84 candidates reached a compromise, and the Division Bench simply recorded it in a "compromise order" directing their appointment, without examining the merits of anyone's claim. Later, many other unsuccessful candidates who had not been part of that compromise approached the High Court from 2016 onwards, demanding the same benefit on grounds of parity; some succeeded before a single judge while others failed, leading to cross-appeals reaching the Supreme Court by both the aggrieved candidates and TANGEDCO.
Decision Breakdown
The Supreme Court held that the 2015 compromise order was not a judgment on the merits and was not an "order in rem" (binding on everyone), but a private settlement binding only on its own parties, so it created no general right for other candidates to claim the same treatment. It distinguished this from the precedent in Aravind Kumar Srivastava, which requires equal treatment for similarly situated persons only where the earlier order was a genuine merits-based adjudication, and even then only for those who approach the courts without undue delay. The Court reaffirmed the constitutional principle of "no negative equality": Article 14 cannot be used to demand that an unjustified benefit given to one group by mistake or concession be extended to everyone else, since a wrong cannot be multiplied in the name of equality. Since the candidates seeking parity had also delayed in approaching the courts, waiting until after the compromise before filing their claims, their appeals were dismissed, while TANGEDCO's appeal (challenging orders that had wrongly extended the compromise benefit to others) was allowed.
Lesson Learnt
If a government body settles a case with certain individuals through a compromise rather than winning or losing on the actual legal merits, that settlement does not create a right for other people in a similar position to demand the same treatment: the Constitution's equality guarantee does not require repeating a mistake or an unmerited concession.