On Wednesday, the Supreme Court ruled that candidates from reserved categories who are meritoriously selected for open categories cannot have their selection counted against their category's reserved quota.
The appeal contesting the Madhya Pradesh High Court's decision was being heard by the bench of Justices C.T. Ravikumar and Sanjay Kumar.
In this instance, candidate segregation was contested in court after the Madhya Pradesh Public Service Commission (MPPSC) published an advertisement in 2019 for 571 State service positions and held preliminary exams in January 2020.
In the meantime, the major test took place in March 2021, and the original provisions were reinstated in the rules after they were revised once more in December 2021. Nonetheless, the revised rule was used to announce the results of the exam held in March 2021.
A High Court judgment in April 2022 declared the amendment ultra vires, directing recruitment as per the original rules. The MPPSC announced a re-conduct of the main exam in September 2022, and revised preliminary results were declared in October 2022.
Some candidates contested this decision in court. Review petitions were filed seeking clarification of the April 2022 judgment, and a fresh writ petition was filed, leading to a High Court judgment in November 2022, allowing candidates to reappear for the main exam.
An appeal against this judgment was dismissed by a Division Bench in January 2023. The Supreme Court rejected interim relief in April 2023 but directed proceedings to remain subject to its final orders.
Supreme Court opined that the process of normalization and the consequential merger of the marks secured by the candidates who appeared in the two main examinations cannot be found fault with.
The bench stated that Rule 4(3)(d)(III) of the Rules of 2015 patently harmed the interests of the reservation category candidates, as even meritorious candidates from such categories, who had not availed any reservation benefit/relaxation, were to be treated as belonging to those reservation categories and they were not to be segregated with meritorious unreserved category candidates at the preliminary examination result stage. As a result, they continued to occupy the reservation category slots which would have otherwise gone to deserving reservation category candidates lower down in the merit list of that category, had they been included with meritorious unreserved category candidates on the strength of their marks.
Supreme Court observed that the State of Madhya Pradesh itself realized the harm that it was doing to the reservation category candidates and chose to restore Rule 4, as it stood earlier, which enabled drawing up the result of the preliminary examination by segregating deserving meritorious reservation category candidates with meritorious unreserved category candidates at the preliminary examination stage itself.
The bench noted that the judgment in Kishor Choudhary vs. State of Madhya Pradesh and another was not subjected to challenge before this Court after the dismissal of the review petitions. The direction therein was to conduct and complete the examination process in accordance with the unamended Rules of the 2015.
Supreme Court observed that it was the later judgment in Harshit Jain and others vs. State of Madhya Pradesh and another that advocated the methodology of holding a special main examination for the reservation category candidates who were found eligible after revising the preliminary examination result in keeping with the unamended Rules of 2015. This direction was found to be justified by the Division Bench, which dismissed the writ appeal by way of the impugned judgment and, in our considered opinion, rightly so. In view of the above, the bench dismissed the appeal.
Case Title: Deependra Yadav and others v. State of Madhya Pradesh and others
Bench: Justices C.T. Ravikumar and Sanjay Kumar
Case No.: Special Leave Petition (C) No. 5817 of` 2023
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