Madhya Pradesh High Court Orders Appointment for Physically Handicapped Candidate Despite Select List Expiry

Court rules that candidate should not be penalized for administrative delays, directs appointment within 60 days  

In a significant ruling, the Madhya Pradesh High Court has directed the appointment of Sonu Singh Narwariya, a physically handicapped candidate, despite the expiration of the select list. The court held that the delay in completing the requisite formalities, such as medical verification, was attributable to the respondents and not the candidate.  

The case revolved around Sonu Singh Narwariya, who had applied for a teaching position under the OBC/LD category and was provisionally selected on October 16, 2024. However, his appointment was delayed due to a lengthy verification process of his disability certificate, which was mandated by the authorities after certain certificates were found forged in other districts.  

Despite Narwariya's timely compliance with all requirements, including appearing for medical examinations as scheduled, the final verification of his disability was only completed after the expiration of the select list's validity on August 20, 2025.  

Justice Ashish Shroti, presiding over the case, emphasized that the petitioner should not be held responsible for procedural delays caused by the respondents. The court noted that Narwariya was certified to suffer from a 40% permanent locomotor disability and met all eligibility criteria for the position.  

Referring to the Madhya Pradesh School Education Service (Teaching Cadre) Rules, 2018, the court recognized that the validity of a select list is typically one year, extendable by six months. However, the court cited the Supreme Court's ruling in Asha Kaul v. State of J&K, which highlighted the obligation of the state to act fairly and not arbitrarily, stating that candidates should not suffer due to administrative inefficiencies.  

The court concluded that denying Narwariya's appointment due to the expiration of the select list, especially when the delay was not his fault, would be unreasonable. It directed the state to issue his appointment order within 60 days from the submission of a certified copy of the judgment.  

This judgment reinforces the principle that administrative delays should not unjustly hinder the rightful appointment of eligible candidates, particularly those with disabilities, emphasizing the need for fair and reasonable actions by state authorities.  

Bottom Line:

Service Law - A candidate cannot be denied appointment due to expiration of the select list validity period if the delay in completing requisite formalities, such as medical verification, is attributable to the respondents and not the candidate.

Statutory provision(s):  

• - Article 226 of the Constitution of India  
• - Madhya Pradesh School Education Service (Teaching Cadre) Rules, 2018, Rule 12(4)

Sonu Singh Narwariya v.State Of Madhya Pradesh, (Madhya Pradesh)(Gwalior) : Law Finder Doc Id # 2819841