Simplified Explanation of the Judgment
In a recent case, the Patna High Court dismissed an appeal filed by a litigant whose application for a Class-IV government job was rejected due to lack of the revised minimum educational qualification. The Court upheld the government’s decision to enforce new rules requiring matriculation (Class 10 pass) for such posts, even though the applicant had originally applied when the requirement was lower.
The background of the case begins in the early 1990s when the petitioner was empanelled for Class-IV government jobs. However, he wasn’t appointed immediately. The recruitment process for such positions continued over the years, and by 2011, the government issued fresh advertisements.
Originally, the eligibility required candidates to have passed at least Class VIII. But this changed in 2011 when the minimum qualification was revised to Class X. A notification from the General Administration Department dated 26.12.2013 clarified that from 12.12.2012 onwards, only matriculates would be considered for appointment.
The petitioner, who did not hold a matriculation certificate, argued that changing the rules in the middle of the recruitment process was unfair. He cited a Supreme Court judgment (K. Manjushree v. State of Andhra Pradesh) to support his claim that rules cannot be altered midway through a selection process.
However, both the learned Single Judge and the Division Bench of the Patna High Court rejected this argument. The Court pointed out that the empanelment of the petitioner dated back to 2012 and was valid only for a year. There was no evidence that he remained empanelled thereafter. Moreover, his application was considered only for the purpose of age relaxation—not for exemption from educational qualification.
The Court also noted that similar petitions by other candidates were previously dismissed in CWJC No. 4693 of 2012 and its connected appeals.
Therefore, finding no merit in the arguments, the High Court dismissed the appeal and upheld the decision of the authorities to reject the application for not meeting the current qualification requirements.
Significance or Implication of the Judgment
This judgment reinforces the authority of the State to revise recruitment rules in line with changing standards and administrative needs. It sends a clear message that empanelment or old eligibility cannot guarantee appointment under new rules, especially when recruitment is long delayed.
For the general public, especially aspiring government job seekers in Bihar, this case highlights the importance of staying updated on revised qualification criteria. It also indicates that courts are likely to favor policy changes that aim to enhance the quality of public service, even if it affects previously empanelled candidates.
Legal Issue(s) Decided and the Court’s Decision with Reasoning
- Whether recruitment rules can be changed after empanelment but before final appointment.
- Court’s Decision: Yes. The Court held that new rules requiring matriculation are applicable to ongoing and future appointments.
- Whether non-matriculate empanelled candidates can claim appointment under old rules.
- Court’s Decision: No. The Court ruled that the empanelment of the appellant was valid only for a limited period, and since no appointment had occurred before the new rules came into effect, the revised qualification criteria applied.
- Whether the change in qualification amounts to changing rules mid-process.
- Court’s Decision: No. The Court found that the selection process had not reached a stage that could be considered midway. Hence, the policy change was valid.
Judgments Referred by Parties
- K. Manjushree vs. State of Andhra Pradesh and Anr., (2008) 3 SCC 512
Judgments Relied Upon or Cited by Court
- CWJC No. 4693 of 2012 (dismissed earlier)
- LPA arising out of CWJC No. 4693 of 2012 (dismissed)
Case Title
Anand Kumar Jha vs. The State of Bihar & Others
Case Number
Letters Patent Appeal No. 212 of 2023
In Civil Writ Jurisdiction Case No. 21973 of 2014
Citation(s)
2025 (2) PLJR 319
Coram and Names of Judges
Hon’ble the Acting Chief Justice Ashutosh Kumar
Hon’ble Mr. Justice Partha Sarthy
Names of Advocates and who they appeared for
Mr. Shanti Pratap, Advocate — For the Appellant
Mr. P.K. Verma (AAG-3) — For the Respondents
Link to Judgment
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