Court Dismisses Petition Seeking Relaxation of Document Submission Deadline for Assistant Professor Post
In a significant ruling, the Madhya Pradesh High Court dismissed a writ petition filed by Smt. Aaradhna Buj, seeking relaxation of the document submission deadline for the recruitment of Assistant Professor (Botany) under the Madhya Pradesh Public Service Commission (PSC). The judgment, delivered by Justice Jai Kumar Pillai, emphasized the mandatory nature of adherence to prescribed timelines in the recruitment process, reinforcing the principles of equality, transparency, and certainty in public employment.
The petitioner, Aaradhna Buj, argued that she was unable to submit the required documents due to ill health, despite being placed on the provisional merit list after clearing the written examination. She contended that her condition, Mixed Connective Tissue Disease (MCTD), prevented her from adhering to the deadlines. The petitioner had requested the court to direct the PSC to accept her documents beyond the prescribed cut-off date and consider her candidature.
The court, however, maintained that the terms of the recruitment advertisement and the subsequent instructions issued were binding and mandatory. Justice Pillai noted that the recruitment process's timelines were extended twice, with the final cut-off allowing submissions until November 11, 2024. Despite these extensions, the petitioner failed to comply, which led to her disqualification.
Citing precedents from the Supreme Court and various High Courts, the judgment underscored that participation in the selection process under interim orders does not confer any vested right to candidates. The court stressed that any deviation from advertised conditions without statutory backing would violate Articles 14 and 16 of the Constitution, which ensure equal opportunity in public employment.
The judgment further clarified that public recruitment processes must be governed by certainty and uniformity, and individual relaxations on equitable grounds would set an unhealthy precedent. Justice Pillai emphasized that the recruitment rules did not provide for relaxation due to personal difficulty or illness, thereby rejecting the petitioner's plea for leniency.
Ultimately, the court ruled that the petitioner's failure to submit her documents within the prescribed timeframe constituted a clear breach of the recruitment process's mandatory conditions. The court concluded that interference at this stage would amount to rewriting the conditions of the advertisement, which is impermissible under law.
The decision reinforces the importance of strict compliance with recruitment timelines and reaffirms the judiciary's commitment to uphold the principles of equality and transparency in public employment.
Bottom Line:
Recruitment process - Adherence to prescribed timelines for submission of documents is mandatory and non-compliance results in disqualification. Relaxation cannot be granted on grounds of personal difficulty or illness in absence of enabling provisions in the advertisement or rules.
Statutory provision(s): Article 226 of the Constitution of India, Article 14, Article 16
Smt. Aaradhna Buj v. State of Madhya Pradesh, (Madhya Pradesh)(Indore) : Law Finder Doc id # 2842544
