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Sanjai Kumar & Ors. v. Dr. Prabhat Kumar & Ors.

Civil Appeal · 2019 INSC 1372Decided 13 Dec 2019
Civil Appeal Nos. 4347-4375 of 2014
Justice Uday Umesh Lalit · Justice M.R. Shah

Background

This batch of contempt petitions arose out of a long-running dispute over appointment of Assistant Teachers in Uttar Pradesh under the Right to Education Act. The Supreme Court had, through a series of interim orders between 2014-2015, directed the State to appoint candidates who crossed certain cut-off marks in the Teacher Eligibility Test, and this ultimately merged into a final 2017 judgment. The petitioners, candidates who were part of a list of 12,091 persons found eligible for appointment, alleged the State had willfully violated these orders by not actually appointing all of them.

Decision Breakdown

The Court traced the entire appointment process through multiple State affidavits and found that out of the 12,091 eligible candidates, only 391 (plus separate ad-hoc appointments) could actually be selected, because many did not participate in counselling, did not opt for certain districts, or did not meet district-specific cut-offs: reasons that had been on record since October 2016 and were never challenged until the contempt petitions were filed roughly a year later. Finding the State's explanation satisfactory and no person appointed outside the Court-mandated criteria, the Court held there was no violation of its orders and closed all the contempt petitions.

Lesson Learnt

A contempt petition requires proof of wilful and deliberate disobedience of a court's specific directions: a petitioner's dissatisfaction with how an administrative selection process played out, without showing the authority exceeded or defied the court's actual mandate, will not succeed as contempt.

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

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