Ravi Oraon vs. The State of Jharkhand & Ors.
Background
Three Scheduled Tribe candidates (Ravi Oraon, Premlal Hembrom, and Surendra Munda) were appointed as Intermediate Trained Teachers in Dhanbad district in 2015. In 2016, the Education Department issued show-cause notices alleging they had not secured the minimum required marks (45%, relaxed to 40% for ST candidates) in their intermediate examinations, after excluding marks they had earned in a vocational subject. Without giving them a real opportunity to contest this recalculation, the Department terminated their services. A Single Judge of the Jharkhand High Court set aside the terminations, but a Division Bench reversed that relief on intra-court appeal, leading to these appeals before the Supreme Court.
Decision Breakdown
The Supreme Court held that the rule excluding vocational-subject marks (Rule 21) was meant only for preparing merit lists for recruitment, not for determining basic eligibility, and that the appellants' marks (with vocational marks included) met the required threshold. It further held that the termination orders violated natural justice because the appellants were never given a fair chance to contest the recalculated marks before being terminated. The Court set aside the Division Bench's judgment and the termination orders, directing that Ravi and Premlal be treated as continuously employed since 2015 with full arrears of pay (though not counted toward promotion-experience criteria), while Surendra, who had since died, was deemed to have died in service, entitling his heirs to arrears of pay and consideration for compassionate employment.
Lesson Learnt
A government employer cannot terminate an employee's service based on a technical recalculation of eligibility without first giving the employee a genuine opportunity to be heard: procedural fairness is not a mere formality, and skipping it can render even a "correct" decision on the merits legally invalid.