The Patna High Court has dismissed writ petitions seeking direction for publication of supplementary/revised results in teacher recruitment, holding itself bound by a Division Bench’s decision that set aside an earlier similar relief. This judgment affirms and enforces the binding nature of precedent set by coordinate jurisdiction within the same High Court for public employment disputes.
Summary
| Category | Data |
|---|---|
| Case Name | CWJC/2337/2024 of Satyam Kumar Vs The State of Bihar |
| CNR | BRHC010097102024 |
| Date of Registration | 07-02-2024 |
| Decision Date | 30-10-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | MR. JUSTICE HARISH KUMAR |
| Court | Patna High Court |
| Bench | Single Judge |
| Precedent Value | Binding within Bihar (subject to possible appeal/review) |
| Overrules / Affirms | Affirms and follows Division Bench judgment in LPA No. 1030 of 2024 |
| Type of Law | Service Law / Public Employment / Judicial Review |
| Questions of Law | Whether the writ court may direct publication of supplementary/revised results after a Division Bench has already denied similar relief in an LPA arising from a like situation. |
| Ratio Decidendi |
The present writ petition, seeking directions to the Bihar Public Service Commission for publication of supplementary/revised results and additional recommendations for appointments as teachers under Advertisement No. 26/2023, is not maintainable in view of the Division Bench’s judgment in LPA No. 1030 of 2024. The court clearly states that where a coordinate or higher bench has considered and set aside similar relief, it is bound to follow that precedent, precluding conflicting orders at the single-judge level. Consequently, judicial propriety and discipline necessitate dismissal of the instant writ petition. |
| Judgments Relied Upon | Division Bench judgment in LPA No. 1030 of 2024, which set aside Single Judge’s direction for similar relief. |
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Judicial discipline requires that a Single Judge follow the judgment of a Division Bench of the same High Court, particularly when the subject matter and relief sought are identical. |
| Facts as Summarised by the Court |
Petitioners are aspirants to primary school teacher posts under Advertisement No. 26/2023, seeking directions for revised/supplementary results and recommendations. Identical relief was earlier granted by a Single Judge in CWJC No. 1151 of 2024, but the Division Bench reversed that order in LPA No. 1030 of 2024. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts in Bihar, and single judges of the Patna High Court on similar factual/law matrices |
| Persuasive For | Other High Courts in service law matters, especially on binding precedent protocol |
| Follows | Division Bench decision in LPA No. 1030 of 2024 |
What’s New / What Lawyers Should Note
- The Single Judge has categorically declined to re-open or re-grant relief already denied by a Division Bench in an LPA, even when the factual matrix is identical.
- Relief for publication of a supplementary or revised result in a public employment recruitment cannot be sought if a Division Bench has already negatived similar claims.
- Lawyers must check the status of appellate proceedings before seeking similar relief in writ jurisdiction, especially after a Division Bench pronouncement.
Summary of Legal Reasoning
- The petitioners, being similarly placed as prior litigants, sought supplementary/revised results and further recommendations for teaching posts under the Bihar Public Service Commission’s recruitment.
- The court noted that a co-ordinate Single Judge had earlier granted similar relief in CWJC No. 1151 of 2024.
- However, that order was set aside by a Division Bench in LPA No. 1030 of 2024.
- Copies of both earlier orders were on record, demonstrating identical legal and factual issues.
- The Single Judge held that in these circumstances, the writ petition must be dismissed “in terms with the order passed by the learned Division Bench,” following the principle of judicial discipline and binding precedent within the same High Court.
Arguments by the Parties
Petitioner
- Sought directions for publication of a supplementary/revised result under Advertisement No. 26/2023.
- Argued for additional recommendation to be made by the Commission for their appointment.
- Cited that identical relief had earlier been granted by a coordinate bench of the court.
Respondent (State and BPSC)
- Relied on the Division Bench decision in LPA No. 1030 of 2024 which had set aside the Single Judge’s order granting identical relief.
Factual Background
The petitioners were aspirants for primary school teacher posts (General/Urdu) under Advertisement No. 26/2023 issued by the Bihar Public Service Commission. After the results were published, they sought a direction to the Commission to issue supplementary or revised results and send additional recommendations to the Education Department for appointment. Identical relief had previously been granted in another writ petition, but was overturned by the Division Bench in appeal. The present petition was filed after these developments.
Statutory Analysis
The judgment does not quote statutory provisions but its reasoning is grounded in the doctrine of binding precedent within the same High Court, particularly regarding judicial review of service/recruitment processes administered by state instrumentalities.
Procedural Innovations
No new procedural innovations have been prescribed or followed in the judgment.
Alert Indicators
- ✔ Precedent Followed – Judgment affirms and strictly follows binding Division Bench precedent on the same issue.