Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-012750-012754 – 2025 |
| Diary Number | 50191/2023 |
| Judge Name | HON’BLE MR. JUSTICE J.K. MAHESHWARI |
| Bench | HON’BLE MR. JUSTICE J.K. MAHESHWARI; HON’BLE MR. JUSTICE VIJAY BISHNOI |
| Precedent Value | Binding on High Courts and subordinate courts |
| Overrules / Affirms | Affirms L. Chandra Kumar; holds T.K. Rangarajan as non-binding |
| Type of Law | Service law; administrative-tribunal jurisdiction in recruitment |
| Questions of Law |
|
| Ratio Decidendi | The Court held that recruitment disputes over certificate interpretation fall squarely within the exclusive jurisdiction of the State Administrative Tribunal under Section 15 of the Administrative Tribunals Act, 1985, and cannot be bypassed by writ petitions under Article 226 except in narrowly defined exceptions (e.g., violation of fundamental rights, breach of natural justice, orders wholly without jurisdiction, or challenge to the vires of the parent statute). T.K. Rangarajan was distinguished as an extraordinary, non-binding order under Article 142. Ordinary recruitment discrepancies do not warrant High Court intervention when a speedy, efficacious tribunal remedy exists. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court |
|
| Facts as Summarised by the Court | The Department of Public Education, Karnataka, invited applications for 15,000 Graduate Primary Teacher posts. Married women OBC candidates submitted parents’ caste-cum-income certificates and were pushed to general merit; they challenged rejections in writ petitions. A Single Judge quashed the provisional select list (18.11.2022); a Division Bench set aside that order and relegated all certificate disputes to KSAT. Appeals to the Supreme Court raised the maintainability of writ petitions when a tribunal remedy exists. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All High Courts and subordinate courts, in service-law disputes with alternative tribunal remedy |
| Persuasive For | State Administrative Tribunals; litigants in recruitment and service matters |
| Overrules | None directly—but T.K. Rangarajan’s reasoning treated as non-binding |
| Distinguishes | T.K. Rangarajan v. Government of Tamil Nadu (2003) 6 SCC 581 |
| Follows | L. Chandra Kumar v. Union of India (1997) 3 SCC 261; Rajeev Kumar & Anr. v. Hemraj Singh Chauhan & Ors. (2010) 4 SCC 554 |
What’s New / What Lawyers Should Note
- Writ petitions challenging recruitment certificate rejections must be filed before the Administrative Tribunal; Article 226 cannot bypass Section 15 of the Administrative Tribunals Act, 1985.
- The Supreme Court reaffirms that T.K. Rangarajan is an extraordinary, non-binding order under Article 142 and does not displace L. Chandra Kumar.
- Exceptions justifying High Court intervention remain limited to fundamental-rights enforcement, violations of natural justice, orders wholly without jurisdiction, or challenges to the vires of tribunal-constituting statutes.
- Administrative Tribunals have plenary powers (Sections 15, 22, 24) and must adjudicate recruitment and service disputes expeditiously—litigants should exhaust these statutory remedies first.
- Interim relief from Supreme Court (03.01.2024, 22.01.2024, 04.10.2024) kept 500 posts reserved; these seats will be filled per KSAT’s final decision.
Summary of Legal Reasoning
- Exclusive Tribunal Jurisdiction: Under Section 15 of the Administrative Tribunals Act, 1985, all recruitment and service disputes must first be litigated before the State Administrative Tribunal.
- Rule of Alternate Remedy: The High Court’s writ jurisdiction under Article 226 is discretionary and ordinarily declines when an effective statutory forum exists (Thansingh Nathmal; Titaghur; Mafatlal; Whirlpool).
- Constitution Bench Authority: L. Chandra Kumar (1997) binds that tribunals are courts of first instance; direct writs are impermissible except in narrow exceptions.
- Non-Binding Exceptions: T.K. Rangarajan was an extraordinary, Article 142 order in unique circumstances (mass dismissals) and does not override Chandra Kumar.
- Scope of Exceptions: Only breaches of fundamental rights, ultra vires actions, natural justice violations, or vires challenges to tribunal statutes justify bypassing the tribunal.
- Application to Facts: The dispute over 481 candidates’ OBC certificates is a routine recruitment discrepancy—not an exceptional circumstance—mandating tribunal adjudication.
Arguments by the Parties
Petitioners (Appellants)
- Writ petitions were maintainable due to “unprecedented” recruitment halt affecting 15,000 posts (invoking T.K. Rangarajan).
- Single Judge correctly quashed the provisional list (18.11.2022) and should have reinstated it rather than relegating to KSAT.
- Left-out appellants in final list (08.03.2023) can be accommodated in remaining vacancies.
Respondent State
- Certificate-interpretation disputes fall within KSAT’s exclusive jurisdiction; writ petitions are not maintainable.
- Only 13,352 of 15,000 posts filled; appointment of appellants depends on KSAT outcome.
- The State will comply with Supreme Court and tribunal orders on all appointments.
Factual Background
In March 2022, Karnataka invited applications for 15,000 Graduate Primary Teacher posts. Examinations held in May; provisional select list (18.11.2022) excluded several married women OBC candidates who produced parents’ caste-cum-income certificates and placed them in general merit. They filed writ petitions; a Single Judge quashed the list and directed reconsideration. A Division Bench reversed, held writs unmaintainable, and sent all certificate disputes to the Karnataka State Administrative Tribunal. The Supreme Court was then called upon to decide maintainability.
Statutory Analysis
- Section 15 (Administrative Tribunals Act, 1985): Grants exclusive jurisdiction to State Administrative Tribunals over recruitment and service matters, extinguishing court jurisdiction except Supreme Court.
- Section 22: Empowers Tribunals to regulate their own procedure, guided by natural justice.
- Section 24: Allows Tribunals to grant interim orders (including without notice in exceptional circumstances).
- Procedure Rules & Timelines: Karnataka Rules mandate a six-month disposal timeline and permit ex parte hearings; Tribunal has contempt, review, and execution powers (Sections 17, 27, 35, 36).
Alert Indicators
- 🚨 Breaking Precedent – T.K. Rangarajan treated as non-binding under Article 142
- ✔ Precedent Followed – L. Chandra Kumar binds exclusive tribunal jurisdiction
- 🔄 Conflicting Decisions – High Courts’ divergence on T.K. Rangarajan vs. Chandra Kumar