The Calcutta High Court reaffirms that writ jurisdiction cannot be invoked to direct the Public Service Commission to publish results or disclose marks when the merit list has already been published and the candidate did not qualify. This judgment upholds existing precedent and is a binding authority for recruitment litigation under State PSCs in West Bengal.
Summary
| Category | Data |
|---|---|
| Case Name | WPA/20158/2025 of ARINDAM SINGHA Vs STATE OF WEST BENGAL AND ORS. |
| CNR | WBCHCA0405972025 |
| Date of Registration | 26-08-2025 |
| Decision Date | 28-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | HON’BLE JUSTICE ANIRUDDHA ROY |
| Court | Calcutta High Court |
| Precedent Value | Binding precedent for similar matters within jurisdiction of Calcutta High Court |
| Type of Law | Service Law / Recruitment under Public Service Commission (PSC), West Bengal |
| Questions of Law | Whether a writ can be issued compelling the PSC to publish merit lists/marks or communicate result/details to candidates after the merit list has already been published and candidate is not qualified. |
| Ratio Decidendi | The Court found that the merit list for the Motor Vehicles Inspector (Non-Technical) recruitment had already been published, and the petitioner did not qualify or come within the zone of consideration. As such, there was no merit in a prayer for fresh direction to disclose individual marks or the merit list. The petition was dismissed accordingly, holding that such relief cannot be extended through writ jurisdiction in these circumstances. |
| Facts as Summarised by the Court | The petitioner sought directions for the immediate publication of results and disclosure of individual marks regarding a PSC recruitment. The PSC placed a report on record, confirming the merit list’s publication and setting out the relevant marks; the petitioner scored below the last UR category recommendation. The court found the petitioner was not in the zone of selection and so writ relief was unwarranted. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts within the jurisdiction of the Calcutta High Court |
| Persuasive For | Other High Courts and State PSCs across India |
What’s New / What Lawyers Should Note
- Reaffirms that when the merit list in a PSC recruitment has already been published and the candidate has not qualified, writ courts will not direct fresh publication or disclosure.
- Establishes that lack of qualification or inclusion in the consideration zone precludes relief in writ jurisdiction for disclosure of marks or merit list.
- Lawyers should be prepared to advise clients that unsuccessful candidates cannot invoke Article 226 or seek mandamus for re-publication of merit lists post selection process conclusion.
Summary of Legal Reasoning
- The Court considered the petitioner’s prayer for a writ of mandamus to direct the publication of the final merit list, disclosure of marks, and other related information regarding a recruitment by the Public Service Commission, West Bengal.
- The PSC submitted a report confirming the merit list had already been published and detailing both the petitioner’s marks and those of the last recommended candidate.
- Upon review, the Court found the petitioner was not within the zone of selection and, therefore, had no standing to seek the relief claimed.
- The Court concluded there was no merit in the petition and dismissed it outright.
Arguments by the Parties
Petitioner
- Sought writ of mandamus directing the PSC to publish the final merit list and communicate the result/candidature status.
- Prayed for individual marks in both parts of the examination as well as disclosure of cut-off marks and selection criteria.
Respondent (Public Service Commission, West Bengal)
- Submitted a report showing the petitioner’s scores and those of the last recommended candidate.
- Affirmed that the merit list had already been published and the petitioner was not amongst the selected candidates.
Factual Background
The petitioner, Arindam Singha, participated in the PSC recruitment for the post of Motor Vehicles Inspector (Non-Technical) advertised under Notification No. 1/2019. Following the release of results, the petitioner did not appear in the list of recommended candidates. He sought through a writ petition the immediate publication and disclosure of merit list, selection criteria, and individual marks. During proceedings, PSC submitted a report detailing the marks of the petitioner and the last selected candidate and stated the merit list was already published.
Statutory Analysis
The judgment considered the scope of writ of mandamus under Article 226 of the Constitution of India, particularly its applicability to the recruitment process once the merit list has been published and when a candidate fails to qualify. No further statutory interpretation or reading down was applied in the judgment.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinion was delivered; the judgment is by a single judge.
Procedural Innovations
No new procedural innovations or guidelines were set by the Court in this judgment.
Alert Indicators
- ✔ Precedent Followed – Existing law and procedure for writ relief in recruitment matters reaffirmed.