MP State Service Examination | SC Upholds Segregation Of Deserving Meritorious Reservation Category Candidates With Meritorious Unreserved Category Candidates At Preliminary Examination Stage Itself
|The Supreme Court upheld the process of segregating deserving meritorious reservation category candidates with meritorious unreserved category candidates at the preliminary examination stage itself under the Madhya Pradesh State Service Examination Rules, 2015.
The State of Madhya Pradesh amended the Madhya Pradesh State Service Examination Rules, 2015 (2015 Rules) in 2020 and subsequently recalled it in 2021. The original Rule 4 of the 2015 Rules outlined the method for preparing the select list, involving the merging of meritorious reservation category candidates with meritorious unreserved category candidates at the final selection stage.
Justice C.T. Ravikumar and Justice Sanjay Kumar observed, “It appears that the State of Madhya Pradesh itself realized the harm that it was doing to the reservation category candidates and chose to restore Rule 4, as it stood earlier, which enabled drawing up the result of the preliminary examination by segregating deserving meritorious reservation category candidates with meritorious unreserved category candidates at the preliminary examination stage itself.”
Sr. Advocates R.Bala Subramanyam, Gaurav Agarwal, and Rakesh Khanna represented the appellants, while AAG Saurabh Mishra and Sr. Advocate Atma Ram N. S. Nadkarni appeared for the respondents.
However, the amended Rule 4, introduced in 2020, altered this process, stipulating that the segregation of candidates from different categories would only occur at the final selection, not during the preliminary/main examination. Despite reverting to the original rule on 20.12.2021, the amended rule was erroneously applied to the ongoing recruitment process.
The High Court of Madhya Pradesh declared Rule 4(3)(d)(III) of the 2015 Rules ultra vires and set it aside, requiring the recruitment process to adhere to the unamended Rules of 2015. The Madhya Pradesh Public Service Commission (MPPSC) was directed to merge and normalise the results of the main examinations. A Division Bench affirmed this Judgment.
The Supreme Court explained how Rule 4(3)(d)(III) of the Rules of 2015 patently harmed the interests of the reservation category candidates, as even meritorious candidates from such categories, who had not availed any reservation benefit/relaxation, were to be treated as belonging to those reservation categories and they were not to be segregated with meritorious unreserved category candidates at the preliminary examination result stage.
“As a result, they continued to occupy the reservation category slots which would have otherwise gone to deserving reservation category candidates lower down in the merit list of that category, had they been included with meritorious unreserved category candidates on the strength of their marks,” the Court added.
Accordingly, the Supreme Court dismissed the appeal.
Cause Title: Deependra Yadav & Ors. v. State of Madhya Pradesh & Ors. (Neutral Citation: 2024 INSC 362)
Appearance:
Appellants: Sr. Advocates R.Bala Subramanyam, Gaurav Agarwal, and Rakesh Khanna; AOR Rakesh Mishra, Aman Varma and Amit Sharma; Advocates Alok Kumar, Ravi Kumar, Shashank Gaurav, Rameshwar Singh Thakur, Samridhi S Jain, Manan Daga and Chaitanya Dixit
Respondents: AAG Saurabh Mishra; Sr. Advocate Atma Ram N. S. Nadkarni; AOR Harsh Parashar, Sunny Choudhary and Shaveta Mahajan; Advocates Akash Lalwani, Abhinav Shrivastava, Shivang Rawat, Harsh Pathak, Mohit Choubey, Ss Rebello and Deepti