Supreme Court Overturns High Court Order on Recruitment of Constable in Bihar Police

The Supreme Court of India recently delivered a crucial judgment in the case of The State of Bihar & Ors. v. Madhu Kant Ranjan & Anr., which revolved around the eligibility and selection criteria for recruitment as a constable in the Bihar Police. The case concerned the non-award of additional marks for an NCC ‘B’ certificate due to late submission of the document. The Supreme Court overturned the Division Bench ruling of the Patna High Court and reinstated the decision of the Single Judge, ruling that submission deadlines outlined in the recruitment advertisement must be adhered to strictly.

Background of the Case

In 2004, the Bihar Police Recruitment Board issued Advertisement No. 1/2004 for the recruitment of constables in the Bihar Police Force. The advertisement mandated that candidates submit self-attested copies of necessary documents along with their application forms. It also provided for the award of additional five marks for candidates possessing an NCC ‘B’ certificate.

The respondent, Madhu Kant Ranjan, applied for the position and participated in the re-measurement and physical test held on September 8, 2006. However, he did not submit his NCC ‘B’ certificate along with his original application form. As a result, he was awarded 12 marks instead of 17, as he was denied the additional five marks for the NCC certificate.

Ranjan later filed a writ petition before the High Court, claiming that he had submitted his NCC certificate before the declaration of results and that his score should be revised to 17 marks. While the Single Judge dismissed his plea, the Division Bench condoned a three-year delay in filing the appeal and ruled in his favor, directing the recruitment authority to award him the additional five marks and appoint him as a constable.

Arguments by the Petitioner (State of Bihar)

The State of Bihar, represented by its counsel, argued that:

The recruitment advertisement clearly stated that all necessary documents must be submitted along with the application form.
The respondent failed to submit the NCC ‘B’ certificate before the cutoff date of February 22, 2004, and only produced it later in 2007.
The decision of the Single Judge was correct in ruling that late submission of documents could not be entertained after the selection process was complete.
Allowing such relaxations would set a dangerous precedent, leading to an influx of post-selection document submissions and litigations.
The Division Bench erred in interfering with the recruitment process by ordering the appointment of the respondent.

Arguments by the Respondent (Madhu Kant Ranjan)

The respondent, in his defense, contended that:

He had submitted his NCC ‘B’ certificate before the final results were declared.
His overall score, including the additional five marks for the NCC certificate, made him eligible for recruitment.
The recruiting authority had initially included his name in the list with 17 marks but later removed it unfairly.
The High Court’s Division Bench rightly exercised its discretion in awarding him the five additional marks.

Supreme Court’s Observations and Ruling

The Supreme Court, after analyzing the facts and legal provisions, ruled in favor of the State of Bihar and set aside the Division Bench order of the Patna High Court. The key observations of the Court were:

The recruitment advertisement mandated that all relevant documents be submitted along with the application form. The respondent’s failure to comply with this requirement disqualified him from receiving the additional marks.
As per the settled legal principle, eligibility and submission criteria outlined in recruitment advertisements must be strictly followed, and deviations cannot be allowed post facto.
The respondent’s argument that he submitted the certificate after the physical test but before the final results did not hold merit as it was not in compliance with the original application submission requirements.
The Division Bench erred in condoning an excessive delay of three years and 55 days in filing the appeal and in interfering with the recruitment process.
The doctrine of fairness in selection must be maintained, and any relaxation of the eligibility criteria must be applied uniformly and not selectively.

The Court categorically held:

“A candidate must comply with all the conditions/eligibility criteria as per the advertisement before the cutoff date unless extended by the recruiting authority. Only those documents that are submitted along with the application form and as required by the advertisement shall be considered.”

The Supreme Court also emphasized that permitting late submission of documents would create uncertainty in recruitment processes and lead to unnecessary litigations, adversely affecting the efficiency of public employment.

Key Legal Precedents Considered

Bedanga Talukdar v. Saifudaullah Khan (2011) 12 SCC 85 – Stressed that recruitment criteria must be strictly followed.
Rakesh Kumar Sharma v. State (NCT of Delhi) (2013) 11 SCC 58 – Held that a candidate must meet all eligibility requirements as per the recruitment advertisement.
State of M.P. v. Raghuveer Singh Yadav (1994) 6 SCC 151 – Established that public employment must follow a strict adherence to eligibility norms.

Final Verdict

In conclusion, the Supreme Court upheld the decision of the Single Judge of the Patna High Court and quashed the Division Bench ruling. The respondent’s claim for additional marks and subsequent appointment as a constable was rejected. The Court reiterated the importance of adhering to recruitment procedures to maintain the integrity of public employment.

This judgment serves as a landmark decision in ensuring transparency and consistency in recruitment processes, reinforcing the principle that eligibility conditions must be strictly followed without exceptions.

Petitioner Name: The State of Bihar & Ors..
Respondent Name: Madhu Kant Ranjan & Anr..
Judgment By: Justice M.R. Shah, Justice B.V. Nagarathna.
Place Of Incident: Bihar.
Judgment Date: 16-12-2021.

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