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R. Ranjith Singh v. The State of Tamil Nadu

Civil Appeal · 2025 INSC 612Decided 1 May 2025
C.A. No.-006305-006306 - 2025 (arising out of SLP(C) Nos. 5137-38 of 2021)
Mrs. Justice B.V. Nagarathna · Justice Satish Chandra Sharma

Background

Under Tamil Nadu's police recruitment rules, Sub-Inspectors of Police are recruited both through open-market direct recruitment (80% of posts) and through a quota for in-service/departmental candidates (20% of posts). A 2017 Government Order and a related rule amendment gave departmental candidates seniority over open-market recruits regardless of their rank in the selection process, which was challenged by the open-market recruits (the appellants) before the Madras High Court and, after an adverse ruling, before the Supreme Court.

Decision Breakdown

The Supreme Court held, relying on its earlier precedents on limited departmental examinations, that once recruitment is made through a competitive selection process, seniority must be fixed strictly according to merit (that is, the rank or marks obtained in that examination) and not by favouring one category of recruits (departmental) over another (open market) as a matter of policy. It found the 2017 Government Order and the corresponding rule amendment to be arbitrary and violative of Articles 14, 16, and 21 of the Constitution, quashed them, and directed the State to recast all seniority lists issued since 1995 purely on the basis of examination marks/rank, and to hold a single common examination for future recruitment.

Lesson Learnt

Seniority among government employees recruited through a common examination process must be based on merit as reflected in the selection results, not on which recruitment channel (open market versus departmental) a candidate came through, anything else offends the constitutional guarantee of equal treatment in public employment.

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

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