Summary of the Judgment
Case Name: Manilal vs. The State of Rajasthan & Ors.
Court: Supreme Court of India
Civil Appeal Number: Civil Appeal No. [SLP (C) No. 13835 of 2022]
Judgement Date: September 10, 2024
Bench: Hon'ble Justice B.R. Gavai and Hon'ble Justice K.V. Viswanathan
Advocates:
For the Appellant: Mr. Nishant Bishnoi
For the Respondent: Mr. Milind Kumar
Acts & Sections Involved:
Rajasthan Panchayati Raj Act, 1994
Rajasthan Panchayati Raj Rules, 1996
Free and Compulsory Education Act, 2009 (Section 23(1))
National Council for Teacher Education (NCTE) Notifications dated 23 August 2010, 29 July 2011, and 13 November 2019
Key Judgements Cited:
Neeraj Kumar Rai & Ors. vs. State of U.P. & Ors.
Sushil Sompura & Ors. vs. State (Education) & Ors.
Baldev Singh & Ors. vs. State of Uttarakhand & Ors.
State of Rajasthan vs. Ankul Singhal (D.B. Special Appeal Writ No. 545 of 2020)
Dinesh Chandra Damor vs. State of Rajasthan
Introduction
The Supreme Court's decision in the case of Manilal vs. The State of Rajasthan & Ors. sheds light on a significant issue concerning teacher recruitment in the State of Rajasthan. The appeal challenged the Rajasthan High Court's Division Bench ruling, which upheld the dismissal of the appellant's writ petition by the learned Single Judge. This case specifically revolves around the minimum qualification criteria for the post of Teacher Grade III Level II under the Rajasthan Panchayati Raj Act, 1994 and the compliance with the NCTE guidelines.
Background of the Case
The appellant, Manilal, applied for the post of Teacher Grade III Level II in the Scheduled Area (TSP) pursuant to an advertisement issued on 11 September 2017. A total of 1,455 posts were advertised, specifying the required minimum educational qualifications in line with the NCTE notifications. The appellant held a Bachelor of Education (B.Ed) degree and applied for the post, but his candidature was rejected on the ground that he had less than 45% marks in his graduation (44.58%).
The key point of contention lay in whether the appellant, who had secured less than 45% marks in his graduation but was admitted to the B.Ed. course before the cutoff date prescribed by the NCTE notification, was eligible for the post.
Core Legal Issue
The crux of the matter hinged on the interpretation of the NCTE notification dated 29 July 2011, which prescribed a minimum of 45% marks in graduation for eligibility in teacher recruitment. The appellant argued that he had been admitted to the B.Ed. course before this notification came into force, and therefore, the new requirement should not apply to him.
Hon'ble Justice K.V. Viswanathan observed:
"It will be improper to discriminate inter se among a homogenous group of students admitted for the academic session 2009-10. It could not be that those students admitted in the first round of counselling would be eligible, even with less than 50% marks in graduation, while the others admitted in the subsequent rounds of counselling would not be."
This quote encapsulates the court’s stance against discriminatory practices in teacher recruitment based on arbitrary cutoff dates.
Previous Rulings and their Relevance
The Supreme Court referred to its earlier decision in Neeraj Kumar Rai vs. State of U.P., where it was held that the minimum qualifying marks should not be applicable to candidates who had already been admitted to the B.Ed. course prior to the enforcement of the NCTE notification. Similarly, in Ankul Singhal’s case, the court ruled that students admitted to teacher training courses before the prescribed date should not be disqualified based on revised eligibility criteria introduced later.
The court noted that in the appellant’s case, he had taken admission in the B.Ed. course on 23 October 2009, which fell before the NCTE’s cutoff date of 31 August 2009. Therefore, the imposition of the 45% minimum marks criterion was unjust.
Contradictions with Lower Court Rulings
The Division Bench of the Rajasthan High Court had relied on the Dinesh Chandra Damor case to dismiss the appellant’s plea. However, the Supreme Court found this comparison flawed. In the Dinesh Chandra Damor case, the candidate had joined the course much later, after the NCTE notification had come into force. The Supreme Court held that the appellant’s case was more akin to that of Rakesh Gaur, where the candidate had taken admission shortly after the appellant but had been granted relief.
This led to the important judicial observation:
"What is sauce for the goose should be sauce for the gander too."
This maxim underscores the need for equal treatment in similar circumstances, and the Court applied it to rectify the High Court’s error in relying on Dinesh Chandra Damor instead of Ankul Singhal and Rakesh Gaur.
Final Verdict and Implications
The Supreme Court allowed the appeal, setting aside the Rajasthan High Court’s ruling. It directed the respondent authorities to regularise the appellant’s appointment as a Teacher Grade III, which had been made provisionally pursuant to an interim order passed during the pendency of the case. The Court also directed that the appellant would not be entitled to back wages for the period he had not worked, but his pay would be regularised with all consequential benefits.
This judgement holds significant implications for teacher recruitment in Rajasthan, especially for candidates who had taken admission in teacher training courses before the revised NCTE guidelines were implemented. The Court emphasised that changes in eligibility criteria cannot be applied retroactively to disadvantage candidates who complied with the earlier rules at the time of their admission.
Key Takeaways for Legal Professionals
Retroactive Application of Law: The judgement reinforces the principle that laws and regulations, particularly in education and employment, cannot be applied retroactively to disadvantage individuals who complied with the rules in place at the time of their admission or appointment.
Equal Treatment for Similarly Placed Individuals: The case highlights the need for consistent treatment of similarly placed individuals. The Court’s reliance on the maxim “What is sauce for the goose should be sauce for the gander” ensures that judicial decisions maintain equity and fairness across comparable cases.
Role of NCTE Notifications in Teacher Recruitment: This judgement brings clarity on the interpretation of NCTE guidelines and how they impact teacher recruitment. It underscores the importance of reading notifications in conjunction with the legal framework that existed at the time of the candidates' admission to teacher training courses.
Judicial Scrutiny of Administrative Actions: The decision demonstrates the judiciary's role in scrutinising administrative actions that may lead to arbitrary or discriminatory outcomes, ensuring that governmental bodies adhere to the principles of fairness and non-discrimination.
This judgement will serve as a guiding precedent for similar cases in India, especially in the context of educational qualifications and recruitment norms. It also stresses the importance of adhering to principles of natural justice and equality when interpreting statutory provisions and their applicability to past events.
Komentáře