Recruitment Dispute in Uttar Pradesh Police: Supreme Court’s Decision on Physical Efficiency Test

The case of Mahendra Pratap Singh & Ors. vs. State of Uttar Pradesh & Ors. revolved around a recruitment dispute regarding the selection process for Ranker Sub-Inspector posts conducted in 2011. The appellants were candidates who participated in the selection process but faced difficulties due to medical ailments during the physical efficiency test. The case eventually reached the Supreme Court after the High Court ruled against their claims.

Background of the Case

The petitioners participated in the 2011 recruitment process for Ranker Sub-Inspectors in the Uttar Pradesh Police. According to them, they were forced to take the physical efficiency test despite suffering from medical conditions. They claimed that a subsequent circular issued by the Competent Authority allowed other candidates to appear for the test later if they had been unable to participate due to illness. However, they were denied the same opportunity.

The appellants approached the Allahabad High Court, seeking permission for a re-test. The High Court, however, ruled that only those candidates who had informed the authorities on or before the test date about their medical condition were eligible for a second chance. The petitioners, dissatisfied with this ruling, appealed to the Supreme Court.

Petitioners’ Arguments

• The petitioners contended that they were medically unfit at the time of the physical efficiency test and were forced to participate despite their condition.
• They argued that denying them a second chance, when other candidates were allowed to retake the test due to similar conditions, was arbitrary and unfair.
• They claimed that they were being placed in a worse position than candidates who had been absent due to illness but had informed the authorities in advance.
• The petitioners sought relief under Article 14 of the Constitution, arguing that they had been denied equal treatment under the law.

Respondents’ Arguments

• The State of Uttar Pradesh opposed the petition, arguing that the selection process was conducted in a fair and transparent manner.
• They contended that candidates who had not raised any objections at the time of the test could not be granted a second chance later.
• They emphasized that the circular allowing a re-test applied only to those who had officially informed the authorities about their illness before the test.
• The government maintained that granting a re-test to the petitioners would set a bad precedent and create logistical challenges in future recruitments.

Supreme Court’s Observations

The Supreme Court carefully examined the claims and counterclaims in the case. The bench, consisting of Kurian Joseph, Deepak Gupta, and Hemant Gupta, made the following key observations:

• The High Court had already ruled that candidates who had informed the authorities before or on the test date were eligible for a re-test.
• The Court acknowledged the petitioners’ grievances but emphasized that they had not provided prior intimation about their medical condition.
• The Court held that the recruitment rules could not be altered retrospectively to accommodate the petitioners.
• However, the Court noted that if any of the petitioners had indeed informed the authorities in advance but were still denied a re-test, they could submit evidence to the Competent Authority for reconsideration.

Supreme Court’s Ruling

The Supreme Court ruled that the High Court’s decision was legally sound and did not require interference. However, the Court provided an opportunity for affected candidates to seek relief:

1. If any petitioner had informed the authorities before the test about their medical condition, they were allowed to approach the Competent Authority with proof.
2. The Competent Authority was directed to verify the claims and take appropriate action within one month.
3. For all other candidates, the appeals were dismissed, and no further relief was granted.

Implications of the Judgment

This ruling reinforces the principle that recruitment processes must be conducted fairly and in accordance with pre-established rules. It highlights the importance of timely communication of grievances by candidates and sets a precedent for future cases involving similar disputes.

Conclusion

The Supreme Court’s ruling in Mahendra Pratap Singh & Ors. vs. State of Uttar Pradesh & Ors. serves as a reminder that recruitment processes cannot be modified arbitrarily after their completion. While recognizing the difficulties faced by the petitioners, the Court maintained that they had failed to follow the proper procedure to claim relief. The decision upholds the integrity of public recruitment examinations while ensuring that legitimate grievances are addressed.

Petitioner Name: Mahendra Pratap Singh & Ors..
Respondent Name: State of Uttar Pradesh & Ors..
Judgment By: Justice Kurian Joseph, Justice Deepak Gupta, Justice Hemant Gupta.
Place Of Incident: Uttar Pradesh.
Judgment Date: 15-11-2018.

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