Supreme Court Resolves UP Teacher Recruitment Dispute After Eight-Year Litigation
The Supreme Court of India recently delivered a significant judgment in Ran Vijay Singh & Ors. vs. State of U.P. & Ors., bringing finality to an eight-year-long dispute concerning the recruitment of Trained Graduate Teachers in Uttar Pradesh. The case arose from multiple re-evaluations of examination answer sheets and conflicting High Court rulings, leading to uncertainty for thousands of candidates. The Supreme Court upheld the third evaluation of the results and provided relief to candidates who had already been appointed.
Background of the Case
On January 15, 2009, the U.P. Secondary Education Services Selection Board issued an advertisement for the recruitment of Trained Graduate Teachers in Social Science. More than 36,000 candidates appeared for the written examination, conducted in a multiple-choice format with OMR sheets. The results of the examination were declared on June 18, 2010, and qualified candidates were invited for interviews held from July 16 to 26, 2010. The final result, incorporating both the written test and interview, was published on September 14, 2010.
Legal Dispute Over Answer Key Errors
After the results were announced, some unsuccessful candidates filed writ petitions before the Allahabad High Court, alleging errors in the official answer key. A single judge dismissed these petitions, citing a lack of statutory provisions for re-evaluation. The ruling relied on the Supreme Court’s decision in Himachal Pradesh Public Service Commission v. Mukesh Thakur (2010), which held that courts should not direct re-evaluation unless explicitly permitted by law.
Despite this precedent, a different single judge of the High Court admitted a batch of 77 writ petitions challenging the correctness of seven questions in the examination. The judge personally reviewed these questions and found discrepancies in the answer key. The judgment, delivered on February 8, 2012, directed the Board to re-evaluate the answer sheets of the petitioners and adjust the merit list accordingly.
Conflicting Rulings and Appeals
The Board and some affected candidates challenged the single judge’s ruling before a division bench of the High Court. However, on March 13, 2012, the division bench upheld the order for re-evaluation. This led the Board to conduct a second re-evaluation of all candidates’ answer sheets, revising the results and altering the merit list.
Subsequently, additional petitions were filed, leading to further judicial review. The High Court, on April 28, 2015, appointed a one-man Expert Committee to reassess the disputed answers. Based on the Expert Committee’s findings, the High Court ordered a third re-evaluation, prompting another round of revised results.
Supreme Court’s Observations
A bench comprising Justices Madan B. Lokur and Deepak Gupta examined the prolonged litigation and judicial interventions in the examination process.
On Judicial Interference in Examinations:
“A complete hands-off approach is not required, but courts should interfere only in rare and exceptional cases. The law is clear that re-evaluation should not be ordered unless there is a statutory provision permitting it.”
On the Role of Examination Authorities:
“The Selection Board had an obligation to conduct the recruitment fairly, but judicial interference created prolonged uncertainty. The judiciary must respect the expertise of examination bodies.”
On the Impact on Candidates:
“This case highlights the need for reforms in public examinations to prevent repeated litigation. Eight years of legal battles have unfairly affected candidates who had secured positions through prior evaluations.”
Final Judgment
The Supreme Court:
- Upheld the third re-evaluation conducted by the Board.
- Directed the Board to publish the final selection list within two weeks.
- Ordered that candidates who had been appointed based on previous results but were now unsuccessful should not be removed from service.
- Instructed the state government to create supernumerary posts to accommodate newly selected candidates without affecting existing employees.
Implications of the Judgment
For Public Examinations
- The ruling reinforces that courts should be cautious in ordering re-evaluations.
- Examination authorities must ensure error-free answer keys to avoid litigation.
For Candidates
- Ensures that those already appointed are not unjustly removed.
- Newly selected candidates are accommodated through supernumerary posts.
For Judicial Review
- Judges must follow precedents restricting intervention in academic matters.
- Future recruitment disputes must be resolved efficiently to avoid long delays.
Key Takeaways
- The Supreme Court upheld the third evaluation of results, ensuring finality in the recruitment process.
- Courts must exercise caution in interfering with public examinations.
- The ruling prevents job losses for previously selected candidates while accommodating newly selected candidates.
This judgment underscores the importance of maintaining integrity in public examinations while ensuring fair treatment for all candidates.
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