Supreme Court Grants Relief to Bihar Judicial Service Candidates: A Landmark Ruling on Document Submission Requirements

The Supreme Court of India has ruled in favor of multiple candidates who were denied selection in the Bihar Judicial Service Examination due to non-submission of original documents at the time of their interview. The case involved appellants Sweety Kumari, Vikramaditya Mishra, and Aditi, whose candidatures were rejected by the Bihar Public Service Commission (BPSC) despite clearing the required cut-off marks.

The judgment provides significant clarity on the interpretation of procedural rules governing judicial service recruitment, particularly concerning document verification requirements. It also addresses the importance of maintaining fairness in selection processes while ensuring that administrative technicalities do not override merit.

Background of the Case

The appellants appeared for the Bihar Judicial Service Examinations (30th and 31st batches) conducted by BPSC. The commission rejected their applications solely because they failed to produce original copies of required certificates at the time of their interview. Their writ petitions challenging this rejection were dismissed by the High Court, prompting them to seek relief from the Supreme Court.

The Supreme Court had to determine whether the BPSC’s rejection of the appellants was legally justified and what appropriate relief could be granted.

Petitioners’ Arguments

The petitioners presented the following arguments before the Supreme Court:

They had fulfilled all eligibility requirements, including possessing the necessary degrees and certificates. Their rejection was based purely on procedural grounds.
Sweety Kumari and Vikramaditya Mishra submitted true photocopies of their character certificates but could not furnish the originals at the time of the interview due to unavoidable circumstances.
Aditi had passed her final law examination but had not received her law degree certificate due to administrative delays. She argued that her eligibility should not be negated because of circumstances beyond her control.
The rejection was arbitrary and discriminatory, as candidates in similar situations had been accommodated in past recruitment processes.

Respondents’ Arguments

The Bihar Public Service Commission defended its decision, arguing that:

The requirement to produce original documents at the time of the interview was clearly mentioned in the recruitment notification.
Allowing exceptions would undermine the integrity of the selection process.
The rejection was consistent with previous High Court rulings that upheld similar decisions.

Supreme Court’s Analysis

The Supreme Court carefully examined the recruitment rules and past precedents. It emphasized that Rule 9 of the Bihar Civil Service (Judicial Branch) Recruitment Rules, 1955 states that candidates “may be required” to produce original certificates at the interview stage. The Court observed that the wording of the rule made the requirement discretionary rather than mandatory.

The Court also referred to its earlier ruling in Aarav Jain v. Bihar Public Service Commission, where it had held that failure to produce original documents at the interview stage did not justify rejection if candidates had otherwise met all eligibility criteria.

The Court ruled that the rejection of the appellants’ applications was unjustified. It stated:

“The production of the original certificates at the time of the interview is not mandatory but directory. The rejection of candidates who were otherwise eligible and meritorious is arbitrary and cannot be sustained.”

Relief Granted by the Supreme Court

The Court granted the following relief:

Sweety Kumari and Vikramaditya Mishra were directed to be accommodated in the 30th Bihar Judicial Service Examination, as they had secured marks well above the cut-off.
Aditi, who had secured marks above the EWS cut-off in the 31st Examination, was to be accommodated in a suitable vacancy in her category.
The Court instructed the Bihar government to adjust these candidates against existing or future vacancies to ensure that they were not unfairly denied employment.

Legal Precedents and Impact

The Supreme Court reinforced the principle that administrative procedural requirements should not become a means to deny deserving candidates their rightful selection. The judgment cited precedents such as:

Charles K. Skaria v. Dr. C. Mathew (1980) – which held that eligibility should be judged based on substantive qualifications rather than procedural technicalities.
Aarav Jain v. BPSC – where the Court had previously ruled against the arbitrary rejection of candidates over document submission issues.

Conclusion

The Supreme Court’s ruling sets an important precedent for recruitment processes, ensuring that merit prevails over bureaucratic hurdles. It affirms that procedural deficiencies should not override substantive qualifications, thereby strengthening fairness in competitive examinations.

Petitioner Name: Sweety Kumari.
Respondent Name: The State of Bihar and Others.
Judgment By: Justice J.K. Maheshwari, Justice K.V. Viswanathan.
Place Of Incident: Bihar.
Judgment Date: 22-09-2023.

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