In a landmark decision, the Supreme Court of India ruled in the case of Vaishali Wadhwani and Mamta Mishra vs. the Madhya Pradesh Public Service Commission (MPPSC). The judgment underscores the significance of upholding justice and integrity in recruitment processes, safeguarding merit-based opportunities for all candidates involved. Let’s delve into how this verdict sets a crucial precedent for fairness and transparency in public service selection. #SupremeCourt #VaishaliWadhwani #MamtaMishra #MPPSC
Facts
- Out of the 1983 candidates qualified for the interview, 1520 were from the list of 1918 candidates declared eligible earlier.
- 463 candidates emerged successful in the special main examination or normalization process.
- All other candidates meeting the ‘Cut Off Marks’ will also be declared successful for the main examination.
- Vaishali Wadhwani and Mamta Mishra filed SLP (C) No 27620 of 2023 against the judgement dated 23.08.2023.
- The MPPSC clarified that only three out of seven petitioners in SLP (C) No 5817 of 2023 had cleared the preliminary examination.
- Vaishali Wadhwani and others partially succeeded in their writ petitions but later filed SLP (C) No. 23514 of 2023.
- The MPPSC conducted the Madhya Pradesh State Service Examination-2019 with preliminary and main examinations.
- Rule 4 of the Rules of 2015 was amended during the process.
- Normalization of main examination results was done by MPPSC with expert advice.
- The total number of candidates who appeared for the preliminary examination was 3,18,130 out of 3,64,877 who registered.
- The interviews for the qualified candidates were scheduled from 09.08.2023 to 19.10.2023.
- Several candidates challenged the decision of the MPPSC to cancel the result of the main examination, arguing that they had already cleared it in the first instance.
- A learned Judge invalidated the decision to conduct a fresh main examination and directed the MPPSC to hold a special main examination for new eligible reservation category candidates.
- The Judge observed that re-conducting the entire main examination would be unjust to candidates who had already cleared it and qualified for interviews.
- Three petitioners in SLP (C) No. 5817 of 2023 appealed against the Judge’s decision before a Division Bench of the High Court.
- The Division Bench dismissed the appeal, stating that the earlier judgment was just, proper, and well-reasoned.
- The MPPSC then filed Writ Appeal No. 2017 of 2023 challenging the decision, claiming an error in applying the normalization process.
- The Division Bench temporarily stayed the earlier judgment, which was later upheld upon dismissal of miscellaneous applications by Vaishali Wadhwani and others on 12.02.2024.
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Analysis
- The process of normalization was done uniformly to make marks comparable for all candidates.
- The unified marks list will be roll number wise.
- Candidates declared in the category mentioned in their online application form.
- Individual grievances of candidates from Madhya Pradesh State Service Examination-2019 were not considered as they were not parties before the High Court.
- Candidates were not given a hearing as the issue was seen as a larger concern.
- Appeal remedy available for candidates who have grievances with the judgment.
- Experts Dr. Vastashpati Shastri and Mr. Indresh Mangal confirmed the transparency of the process of bringing candidates to an even platform.
- Amended Rule 4 of 2015 provided adjustment and segregation of candidates at the time of final selection, not at the time of the preliminary/main examination.
- Lapse occurred due to the amendment of a service rule and subsequent recall, affecting an ongoing recruitment process.
- Multiple challenges before the High Court of Madhya Pradesh due to the amended rule application.
- All relevant points comprehensively addressed by senior counsel/counsel for the parties.
- Experts who guided MPPSC in normalization process explained the methodology adopted.
- Marks merger after normalization resulted in candidates being ousted from specific slots.
- Normalization process found consistent with legal requirements by the Court.
- Normalization involves adjusting marks obtained by students in different timing sessions to a certain number.
- I.A. No 228055 filed by 182 candidates to support petitioners in a related case.
- Reservation category slots occupied by some candidates caused deserving candidates lower in merit list to miss out.
- Amended Rule 4 applied to the ongoing recruitment process of 571 vacant posts.
- Process of normalization and marks merger ruled faultless.
- Rule 4(3)(d)(III) of 2015 harmed reservation category candidates’ interests by not segregating meritorious candidates at the preliminary examination stage.
- Similar reasons as in another case led to the dismissal of this special leave petition.
- Preliminary examination result declared on 21.12.2020 applying the amended Rule 4.
- Courts should not substitute their judgment for that of a selection committee in recruitment processes.
- Normalization techniques help in comparing values from different data sets by eliminating scale variations.
- Decisions made by expert bodies like Public Service Commissions should not be lightly interfered with.
- Interference in public employment selection processes should generally be avoided to maintain autonomy and integrity.
- Reservations in public services are not rigid ‘slots’ and should not foreclose merit-based opportunities in the open category.
- State of Madhya Pradesh restored a rule to segregate meritorious reservation category candidates with unreserved category candidates at the preliminary examination stage.
- Candidates belonging to reservation categories can be selected in the ‘open category’ based on merit without counting against reserved quota.
- The judgment in Kishor Choudhary was not challenged before the Court after the dismissal of review petitions.
- The later judgment in Harshit Jain advocated holding a special main examination for reservation category candidates as per unamended Rules of 2015.
- The Division Bench justified the direction in the Harshit Jain case and rightly dismissed the writ appeal.
- The impugned judgment by the High Court at Jabalpur in Writ Appeal No. 1706 of 2022 is upheld.
- The civil appeal arising out of SLP (C) No. 5817 of 2023 is dismissed for lack of merit.
- SLP (C) Nos. 23514 and 27620 of 2023 are not considered on merits.
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Decision
- Examination process to be conducted and completed according to unamended Rules of 2015
- Parties to bear their own costs
- Preparation of all five lists and creation of common list of eligible candidates
- Declaration of results roll number wise
- Pending I.A.s to be dismissed
- Determination of cut off marks for unreserved category
- Dismissal of two SLPs
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Case Title: DEEPENDRA YADAV Vs. STATE OF M.P. (2024 INSC 362)
Case Number: C.A. No.-005604-005604 – 2024
