Amrit Yadav v. State of Jharkhand & Ors. (2025 INSC 176)
Headnotes:
Administrative Law – Public Employment: Recruitment process must strictly adhere to the conditions of the advertisement.
Constitutional Law – Articles 14 & 16: Appointment procedures must be transparent and follow due process.
Service Law – Termination of Employment: Candidates selected in violation of rules cannot claim a vested right in employment.
Judicial Review: Courts can intervene where the selection process violates statutory provisions.
Detailed Summary:
The case revolves around the recruitment of Class-IV employees in Jharkhand. The appellant was appointed in 2018, but a legal challenge led to a High Court ruling in 2019 that the selection process was unlawful due to the inclusion of interviews not mentioned in the 2010 advertisement. The appellant's appointment was subsequently terminated. The Supreme Court upheld the termination, ruling that the state acted correctly by preparing a fresh panel in compliance with court orders. The Court emphasized that recruitment processes must be transparent and follow the originally advertised criteria.
Background: The case involved a recruitment process for Class-IV employees in Jharkhand. The selection process deviated from the advertised conditions, particularly by introducing an interview component not mentioned in the initial notification.
High Court Decisions: The Single Judge and Division Bench directed the preparation of a fresh merit list excluding interview marks. The affected candidates, including the appellant, were terminated.
Supreme Court’s Decision: Upheld the High Court’s decision, ruling that appointments made against advertised terms are illegal.
Key Findings:
Violation of Advertisement Terms: Any deviation from the original advertisement is unlawful.
Lack of Natural Justice: The terminated candidates were not impleaded in the earlier litigation.
Delay in Challenging the Decision: The appellant took over three years to approach the Supreme Court, which weakened his case.
Final Holding: Dismissed the appeal, affirming the termination of the appellant’s appointment.