Supreme Court Grants Relief to Teacher in Rajasthan Eligibility Dispute

The case of Manilal vs. State of Rajasthan & Ors. revolves around the eligibility criteria for the post of Teacher Grade III Level II in the Scheduled Area (TSP) under the Rajasthan Panchayati Raj Act, 1994. The Supreme Court overturned the Rajasthan High Court’s decision and reinstated the appellant, providing relief in line with previous judgments concerning candidates with pre-2011 admissions in teacher training courses.

Background of the Case

The Rajasthan government issued an advertisement on September 11, 2017, for the recruitment of 1,455 Teacher Grade III Level II positions in the TSP Area. The eligibility criteria for applicants included minimum percentage requirements in graduation for various categories.

The appellant, Manilal, applied for the position and met all the qualifications except one—his graduation percentage was 44.58%, below the 45% mark required in a notification issued on August 31, 2009. However, he had been admitted to his Bachelor of Education (B.Ed.) course on October 23, 2009, before the enforcement of the new rules.

Despite meeting all other qualifications, his application was rejected, leading to legal action.

2018: The appellant filed a writ petition (SB Civil Writ No. 16005 of 2018) before the Rajasthan High Court.
November 27, 2018: The Single Judge dismissed the petition, ruling that his eligibility was determined based on the August 31, 2009, notification.
2019: The appellant filed a Special Appeal (DB Special Appeal Writ No. 997 of 2019), but the Division Bench upheld the Single Judge’s ruling.
2021: The appellant relied on the Supreme Court’s judgment in Neeraj Kumar Rai vs. State of U.P. to challenge the rejection.
September 10, 2024: The Supreme Court ruled in favor of the appellant, setting aside the Rajasthan High Court’s judgment.

Legal Arguments

Arguments by the Appellant (Manilal)

He was admitted to his B.Ed. course before July 29, 2011, when the National Council for Teacher Education (NCTE) introduced the requirement for a minimum graduation percentage.
The Supreme Court’s ruling in Neeraj Kumar Rai held that candidates admitted before July 29, 2011, were not required to meet the minimum percentage criteria.
The Rajasthan government had previously accepted similar candidates under a revised notification, but he was arbitrarily excluded.
The rejection violated Article 14 (Right to Equality) of the Constitution of India.

Arguments by the Respondents (State of Rajasthan)

The eligibility criteria were clearly laid down in the August 31, 2009, notification, and the appellant did not meet the required marks.
The notification applied uniformly to all candidates, and exceptions could not be made for specific individuals.
The judgment in Neeraj Kumar Rai applied only to Uttar Pradesh and was not binding on Rajasthan.
The recruitment process had already been completed, and reopening the matter would disrupt the selection process.

Supreme Court’s Observations

1. Applicability of the NCTE Notification

The Supreme Court referred to the NCTE’s supplementary notification of November 13, 2019, which clarified that candidates admitted before July 29, 2011, were not required to meet the minimum percentage criteria.

“The appellant’s admission to the B.Ed. course on October 23, 2009, predates the enforcement of the minimum percentage rule, and therefore, he cannot be excluded based on the August 31, 2009, notification.”

2. Inconsistency in Government Policy

The Court found that the Rajasthan government had accepted similarly placed candidates in other recruitment cycles but had unfairly excluded the appellant.

“It would be improper to discriminate inter se among a homogenous group of students admitted for the academic session 2009-10.”

3. Relevance of Previous Judgments

The Court ruled that the Neeraj Kumar Rai judgment applied nationwide and was not restricted to Uttar Pradesh.

“The principles established in Neeraj Kumar Rai must be uniformly applied across states to ensure fairness in teacher recruitment.”

4. Legality of the High Court’s Decision

The Supreme Court held that the Rajasthan High Court had erred in dismissing the appellant’s plea, as his eligibility should have been assessed in light of the subsequent NCTE clarification.

“The High Court failed to consider the effect of the November 13, 2019, notification, which retroactively protected candidates in the appellant’s position.”

Final Verdict

The Supreme Court issued the following directives:

The Rajasthan High Court’s judgment dated April 27, 2022, was set aside.
The appellant’s appointment as Teacher Grade III Level II was reinstated.
The respondent authorities were directed to treat the appellant’s employment as regular and provide consequential benefits.
Back wages were not granted, but the appellant’s pay and seniority were protected.

This ruling ensures fairness in teacher recruitment and clarifies the applicability of NCTE guidelines in cases where eligibility criteria were changed after candidates had already been admitted to teacher training courses.

Petitioner Name: Manilal.
Respondent Name: State of Rajasthan & Ors..
Judgment By: Justice B.R. Gavai, Justice K.V. Viswanathan.
Place Of Incident: Rajasthan.
Judgment Date: 10-09-2024.

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