Kerala PSC Rank List Restoration: Supreme Court Grants Relief to Candidate Priya B.M.

The Supreme Court of India recently delivered a significant verdict in the case of Priya B.M. v. Kerala Public Service Commission & Ors., addressing an employment dispute concerning the Kerala Public Service Commission (PSC) rank list. The case revolved around the petitioner, Priya B.M., who had been excluded from the rank list despite similar candidates being granted relief earlier by the Supreme Court.

The primary issue before the Court was whether Priya B.M. should be granted relief based on the precedent set in Swapna Sukumar & Ors. v. State of Kerala & Ors. and Abokare K. v. State of Kerala & Ors. The High Court had denied relief, holding that the previous order applied only to the parties in those cases. However, the Supreme Court took a different view.

Petitioner’s Argument

The petitioner, Priya B.M., presented the following arguments before the Supreme Court:

• She was part of the same rank list dated 14.06.2011, in which another candidate, Abokare K. (ranked 25), was granted relief by the Supreme Court.
• The Administrative Tribunal and High Court failed to recognize that her case was identical to those previously decided in favor of other candidates.
• Denying her appointment while allowing others in similar situations amounted to discrimination and unfair treatment.
• Since the Supreme Court had already ruled in favor of similarly placed candidates, her exclusion was arbitrary.

Respondent’s Argument

The Kerala Public Service Commission (PSC) countered the claims, stating:

• The relief granted in Swapna Sukumar & Ors. was limited only to the petitioners in that case.
• The rank list had already expired, and fresh appointments were being made under a new selection process.
• Extending relief to additional candidates would set a precedent that could burden the recruitment system and disrupt government employment policies.

Supreme Court’s Observations

The Supreme Court, led by Justice Kurian Joseph and Justice R. Banumathi, examined the arguments and made the following observations:

“The appellant herein belongs to the same rank list dated 14.6.2011 and was at rank No.23. In the case of another similarly situated candidate, this Court on 5.10.2015 in Abokare K. v. State of Kerala & Ors. has granted relief. We are informed that Abokare K. is rank No.25 in the rank list.”

The Court highlighted that the High Court and the Administrative Tribunal had overlooked this crucial fact.

Judgment

The Supreme Court set aside the judgments of the High Court and the Administrative Tribunal. The key directives of the ruling include:

• The name of Priya B.M. shall be restored in the rank list of 04.06.2011.
• The Kerala PSC must operate the rank list in her case and issue an appointment order within two months from the date of production of the Supreme Court order.
• Although the rank list had expired, the Court granted relief due to the peculiar facts and circumstances of the case, ensuring consistency with previous judgments.

Implications

This judgment reaffirms the importance of equal treatment in government employment. Key takeaways include:

• Candidates in similar situations cannot be treated differently by government authorities.
• Expired rank lists do not automatically negate claims if an unfair exclusion has occurred.
• The Supreme Court has the authority to intervene in service matters when precedents are ignored by lower courts.

The ruling ensures fairness in recruitment processes and upholds the principle that candidates who are similarly placed must be treated equally.

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Download Judgment: Priya B.M. vs Kerala Public Servic Supreme Court of India Judgment Dated 13-04-2017.pdf

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