Supreme Court Upholds Reservation Rules in UP Higher Education Recruitment

The case of Dr. Babloo Singh & Ors. vs. State of Uttar Pradesh & Ors. revolved around the applicability of reservation rules in the recruitment of lecturers in aided postgraduate and undergraduate colleges in Uttar Pradesh. The Supreme Court had to determine whether vacancies should be clubbed together subject-wise and college-wise for applying reservation rules.

The petitions before the Supreme Court challenged an order of the Allahabad High Court, which had turned down a reference made to a larger bench regarding key questions on reservation policies. The Supreme Court upheld the High Court’s decision, affirming the applicability of reservation rules as interpreted in previous judgments.

Background of the Case

The issue arose when the Uttar Pradesh Higher Education Service Commission issued advertisements for the recruitment of lecturers in aided postgraduate and undergraduate colleges affiliated with state universities. The controversy centered on whether reservation rules should be applied collectively to all vacancies across colleges or separately for each college and subject.

In earlier cases, particularly Dr. Vishwajeet Singh & Ors. vs. State of U.P. and the Full Bench ruling in Heera Lal vs. State of U.P., the Allahabad High Court had ruled that reservation must be applied college-wise and subject-wise rather than across all vacancies clubbed together.

Arguments by the Petitioners

• The reservation rules under the UP Act No.4 of 1994 should be applied collectively to all vacancies in different colleges, ensuring a uniform distribution of reserved seats.
• Clubbing vacancies for reservation purposes would promote equity and better representation of reserved categories.
• The previous decisions in Dr. Vishwajeet Singh and Heera Lal should be reconsidered as they improperly restricted the application of reservation rules.
• Different colleges should not be treated as independent units for reservation purposes.

Arguments by the Respondents (State of Uttar Pradesh)

• The existing judgments correctly interpreted the reservation rules and must be followed.
• Each college operates as a distinct entity with separately sanctioned posts, so reservation must be applied independently for each college and subject.
• Applying reservation collectively to all vacancies across colleges would violate the principle of local institutional autonomy.

Supreme Court’s Judgment

The Supreme Court upheld the previous rulings, affirming that:

• Reservation rules under UP Act No.4 of 1994 should be applied separately for each college and subject.
• The clubbing of vacancies across different colleges for reservation purposes was not legally permissible.
• The Allahabad High Court’s decisions in Dr. Vishwajeet Singh and Heera Lal were correctly decided and required no reconsideration.
• The larger bench of the Allahabad High Court was justified in turning down the reference for reconsideration.

The Court stated:

“We see no reason to entertain these special leave petitions. The questions as are sought to be raised now had already been considered and decided in Dr. Vishwajeet Singh’s case, which was affirmed by this Court.”

Implementation of the Judgment

The Supreme Court directed the following actions:

• All future recruitments of lecturers in aided postgraduate and undergraduate colleges must follow the principle of applying reservation subject-wise and college-wise.
• The UP Higher Education Service Commission must ensure compliance with this rule in all future recruitment processes.
• No further petitions challenging this interpretation would be entertained.

Significance of the Judgment

This judgment reinforced the principle that reservation policies must be implemented at the institutional level rather than collectively across different colleges. It upheld institutional autonomy while ensuring that reservation benefits were applied fairly within each college.

The ruling provides clarity for recruitment authorities, preventing confusion regarding the interpretation of reservation policies in state-aided educational institutions.

Conclusion

The Supreme Court’s decision in this case affirms the existing framework for applying reservation rules in higher education recruitment. By upholding previous rulings, the Court maintained consistency in policy interpretation, ensuring that each college and subject remains a distinct unit for reservation purposes.

This ruling serves as a landmark precedent in higher education employment law, emphasizing institutional autonomy while safeguarding the rights of reserved category candidates.

Petitioner Name: Dr. Babloo Singh & Ors..
Respondent Name: State of Uttar Pradesh & Ors..
Judgment By: Justice Uday Umesh Lalit, Justice R. Subhash Reddy.
Place Of Incident: Uttar Pradesh.
Judgment Date: 27-11-2018.

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