The Uttarakhand High Court holds that the formal declaration of written examination results and overall merit lists is not mandatory prior to the stage of document verification; the process established under the Uttarakhand Public Service Commission Rules, 2013, is to be followed. The judgment upholds existing procedure and confirms limited judicial intervention at the pre-final result stage. This decision is binding authority for subordinate courts and all recruitments conducted under the same statutory framework.
Summary
| Category | Data |
|---|---|
| Case Name | WPSS/1695/2025 of LAL BAHADUR CHAUHAN Vs UTTARAKHAND PUBLIC SERVICE COMMISSION |
| CNR | UKHC010163472025 |
| Date of Registration | 14-10-2025 |
| Decision Date | 17-10-2025 |
| Disposal Nature | DISPOSED |
| Judgment Author | HON’BLE MR. JUSTICE MANOJ KUMAR TIWARI |
| Court | High Court of Uttarakhand |
| Precedent Value | Binding on recruitments governed by Uttarakhand Public Service Commission (Procedure & Conduct of Business) Rules, 2013 |
| Overrules / Affirms | Affirms Rule-based process and dismisses similar prior writ petition (WPSS/1555/2025) |
| Type of Law | Service Law / Public Employment Recruitment |
| Questions of Law |
|
| Ratio Decidendi | The Uttarakhand Public Service Commission is legally obliged to display the marks of all candidates only after the final results are declared, as per Rule 45 of the 2013 Rules. The stage-wise conduct of recruitment, including calling candidates for document verification based on notified criteria and not publishing marks/merit lists prior thereto, adheres to the statutory rules. Judicial interference is not warranted prior to the declaration of final results, especially where the candidate’s exclusion from document verification is attributable to not meeting the notified cut-off. Petitioner may seek recourse after results if irregularity in lower-scoring candidate selection surfaces. |
| Judgments Relied Upon | WPSS/1555/2025 (dismissed similar claim regarding answer sheet) |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Rule 45 and Rule 71(7) of Uttarakhand Public Service Commission (Procedure and Conduct of Business) Rules, 2013. |
| Facts as Summarised by the Court | Petitioner contended that candidates were called for document verification prior to formal result declaration and sought direction for publication of marks/merit lists and amended cut-offs before final selection; the Commission explained process per rules and prior notifications. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities administering selections under Uttarakhand Public Service Commission (Procedure & Conduct of Business) Rules, 2013 |
| Persuasive For | Other High Courts (for analogous statutory recruitment procedures) |
| Follows | Rule 45 & Rule 71(7) of Uttarakhand Public Service Commission (Procedure & Conduct of Business) Rules, 2013; Dismissal of WPSS/1555/2025 |
What’s New / What Lawyers Should Note
- High Court affirms that the marks of all candidates need only be displayed after final result declaration, as per Rule 45.
- Disclosure of written exam results and merit lists before document verification is not mandated by law.
- A clear distinction is reinforced between calling candidates for document verification and the stage of publishing the final results/marks.
- Judicial intervention is limited at the pre-final result stage; petitioners must await completion of the statutory process unless manifest illegality is shown.
- The procedure for granting answer sheet access is available only after the selection process is complete, following Rule 71(7).
Summary of Legal Reasoning
- The Court examined the recruitment process under the Uttarakhand Public Service Commission (Procedure and Conduct of Business) Rules, 2013, particularly Rule 45 regarding publication of marks post-final result.
- Submissions from the Public Service Commission clarified that as per statutory rules, only the scores of all candidates are to be uploaded on the website after final results are declared—not prior to document verification.
- Reliance was placed on Rule 71(7) regarding answer sheet access, which is conditioned on completion of the selection process and subject to the Commission’s procedures.
- The Court noted that calling candidates for document verification in multiples of available vacancies was compliant with notified procedure.
- Reference was made to dismissal of an earlier, similar writ petition (WPSS/1555/2025), where the prayer for answer sheet copies at a pre-final stage was declined.
- The Court found that there is a statutory presumption that candidates not called for document verification scored below the last cut-off, and judicial intervention is not warranted unless post-final result irregularities can be established (reserving liberty for such claims if substantiated later).
Arguments by the Parties
Petitioner
- Sought mandamus to direct the Commission to declare written exam results and publish merit lists of all candidates, including individual marks, before document verification or final result.
- Challenged the propriety of calling candidates for document verification prior to formal result publication.
- Requested release of amended cut-off marks.
Respondent (Public Service Commission)
- Submitted that a notification was issued calling top 113 candidates for document verification based on existing vacancy-multiplier criteria.
- Pointed to Rule 45, asserting that marks would be displayed only after declaration of final results.
- Referred to Rule 71(7) for procedure regarding answer sheet access after completion of the selection process.
- Cited previous dismissal of similar writ petition (WPSS/1555/2025).
- Affirmed that all rules were being strictly followed and final select list/marks would be published after document verification.
Factual Background
The petitioner participated in the recruitment for Foreman Instructor posts conducted by the Uttarakhand Public Service Commission. After a written examination held on 07.08.2024, the petitioner claimed that certain candidates were called for document verification before the declaration of written examination results and merit list, which he alleged was improper. The recruitment was being conducted for 37 vacancies, and as per the Commission, 113 candidates (three times the vacancies) were notified for document verification. The petitioner sought judicial direction for immediate publication of the marks and merit list prior to the document verification or final result.
Statutory Analysis
- Rule 45 of the Uttarakhand Public Service Commission (Procedure and Conduct of Business) Rules, 2013, mandates that marks of all candidates are to be displayed on the Commission’s website only after declaration of the final results.
- Rule 71(7) allows candidates to seek copies of answer sheets or inspection only after completion of the selection process, subject to procedures framed by the Commission.
- The Court gave a narrow and strict interpretation, limiting candidate entitlements to those explicitly provided after result declaration and completion of the selection process.
Alert Indicators
- Precedent Followed – Existing law and commission procedure under recruitment rules affirmed.