Where the High Court has already upheld the validity of a recruitment selection procedure in a prior writ appeal involving identical factual and legal issues, subsequent challenges raising the same contentions must be dismissed unless distinguishing grounds are demonstrated. The Division Bench reaffirms the binding nature of its prior decision, underlining the principle of judicial discipline and consistency, and affirms this as binding precedent for the jurisdiction.
Summary
| Category | Data |
|---|---|
| Case Name | WA/624/2025 of Laxminarayan Gayakwad Vs State of Chhattisgarh |
| CNR | CGHC010267872025 |
| Date of Registration | 19-08-2025 |
| Decision Date | 02-09-2025 |
| Disposal Nature | DISMISSED |
| Judgment Author | Hon’ble Chief Justice Ramesh Sinha (for the Bench) |
| Concurring or Dissenting Judges | Hon’ble Shri Justice Bibhu Datta Guru (Concurring) |
| Court | High Court of Chhattisgarh |
| Bench | Division Bench: Hon’ble Chief Justice Ramesh Sinha, Hon’ble Shri Justice Bibhu Datta Guru |
| Precedent Value | Binding on all benches of the High Court of Chhattisgarh, persuasive elsewhere |
| Overrules / Affirms |
|
| Type of Law | Service Law – Recruitment / Reservation Policy |
| Questions of Law | Whether a selection process previously upheld on identical facts and legal contentions can be re-opened in subsequent intra-court appeals without new distinguishing grounds. |
| Ratio Decidendi |
The High Court held that once it has conclusively adjudicated the validity of a recruitment selection process in an earlier decision, subsequent petitions challenging the same process on identical facts and contentions are liable to be dismissed to maintain judicial consistency. No distinguishing features or additional grounds having been shown, the court bound itself to its previous judgment, affirming adherence to judicial discipline. The principle of estoppel also applies to petitioners who participated in the process without protest. Judicial pronouncements must be uniform where facts and issues are identical. |
| Judgments Relied Upon |
|
| Logic / Jurisprudence / Authorities Relied Upon by the Court | Judicial discipline; doctrine of binding precedent; Supreme Court guidance on quashing selection processes |
| Facts as Summarised by the Court | The appellant, a constable, challenged the recruitment process for police posts, alleging erroneous preparation of merit list and misapplication of reservation, particularly with respect to female and departmental candidates. The court, however, noted that these issues had been identically raised and already decided in a previous writ appeal, which was dismissed. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All Benches, Single Judges, and subordinate courts within the jurisdiction of the High Court of Chhattisgarh |
| Persuasive For | Other High Courts and any forums considering similar recruitment-selection challenges |
| Follows |
|
What’s New / What Lawyers Should Note
- Affirms that if the High Court has already upheld a recruitment selection process in a prior, identical challenge, subsequent appeals raising the same issues will summarily be dismissed absent new distinguishing grounds.
- Reiterates the obligation of judicial discipline — later benches must follow prior Division Bench decisions on identical facts and questions of law.
- Cites estoppel for candidates who participated in the recruitment process without timely protest — such candidates cannot later challenge the process after being unsuccessful.
- Lawyers should be cautious before filing repetitive appeals with identical contentions previously rejected by the court.
Summary of Legal Reasoning
- The court condoned delay in filing the intra-court appeal but focused on the merits as previously decided in the court’s own Division Bench ruling in Writ Appeal No. 481/2024, 06.09.2024.
- On a review of submissions and the record, the Division Bench noted that the challenge to the validity of the selection/recruitment procedure, including alleged improper reservation implementation, mirrored issues already considered and rejected in WA No. 481/2024.
- The reasoning emphasized judicial discipline and the necessity of consistency in judicial decisions for identical factual and legal matrices, absent any distinguishing factors or new arguments.
- The court also reaffirmed that where a petitioner participated in the recruitment process without protest but challenges the process only after being unsuccessful, the doctrine of estoppel applies.
- The court relied on the Supreme Court’s ratio in Tajvir Singh Sodhi v. State of Jammu & Kashmir & Others (2023 SCC OnLine SC 344) regarding the grounds for quashing recruitment processes.
- The Division Bench thus dismissed the present appeal as being devoid of merit, reiterating its prior binding stance.
Arguments by the Parties
Petitioner
- Respondent authorities deviated from the settled recruitment rules, particularly by preparing the merit list with the reservation roster at the preliminary stage, including unqualified candidates, and failing to prepare post-wise merit lists.
- Rules and advertisement did not permit female candidates for the Platoon Commander post; reservation calculations thereby erroneously included ineligible candidates.
- Claimed flawed application of both female and departmental reservation led to meritorious candidates being excluded.
- Pointed out that the Single Judge’s earlier order itself held similar inclusion of female candidates at the physical efficiency test stage to be illegal and thus sought consistent application at the preliminary stage.
Respondents (State and Examination Board)
- Controversy is covered by the earlier Division Bench decision in Writ Appeal No. 481/2024, which upheld the selection process; principle of judicial discipline mandates conformity to that ruling.
- Asserted that the procedure was fair, transparent, and in accordance with the applicable rules; allegations of procedural or reservation violation are baseless.
- No prejudice caused to the appellant — all claims are misconceived.
- Urged for dismissal of the appeal at the threshold, applying the ratio of the earlier judgment.
Factual Background
The appellant, a candidate for recruitment to police posts in Chhattisgarh, challenged both the manner in which the merit list for the Mains Examination was prepared by the authorities and the application of reservation policies, arguing that erroneous inclusion of unqualified female and departmental candidates prejudiced his own eligibility. He had raised these issues before the Single Judge, whose order dismissed his writ petition and subsequent review petition. The appellant then filed the present intra-court appeal.
Statutory Analysis
- The court discussed the Rules of 2021, specifically provisions regarding merit list preparation, reservation of posts for female and departmental candidates, and their application at preliminary and later stages of the selection process.
- Cited Rule 6(8), Rule 11(6), and Rule 11(7) concerning eligibility, horizontal female reservation, and departmental reservation.
- Referred to the terms of the official recruitment advertisement dated 17.09.2021.
Alert Indicators
- ✔ Precedent Followed – The judgment follows and applies earlier binding Division Bench precedent and maintains judicial consistency.
Citations
- 2025:CGHC:44833-DB
- Reference to: Tajvir Singh Sodhi v. State of Jammu & Kashmir & Others, 2023 SCC OnLine SC 344
- Judgment in Writ Appeal No. 481/2024 (Chhattisgarh HC, decided 06.09.2024)