Court Finds Selection of Candidates with Negligible Marks Arbitary and Orders Fresh Exercise with Minimum Qualifying Standards
In a landmark judgment, the Rajasthan High Court, Jaipur Bench, presided over by Justice Anand Sharma, quashed the recruitment list for Class-IV employees due to the arbitrary selection of candidates who secured negligible marks. The court deemed the recruitment process as violative of Articles 14 and 16 of the Constitution, which guarantee equality before the law and equal opportunity in public employment.
The case, titled Vinod Kumar v. State of Rajasthan, was brought forth by petitioners Vinod Kumar and Anju, who challenged the recruitment process after they were excluded despite vacancies in their respective categories. The petitioners argued that the selection process, which allowed candidates with normalized marks as low as 0.0035, was arbitrary and failed to maintain minimum standards of merit.
The Rajasthan Staff Selection Board had conducted a written examination for 52,453 posts, which included negative marking and normalization due to multiple shifts. However, the normalization process resulted in candidates with negative raw marks being artificially elevated to near-zero marks, leading to their selection.
The court observed that the recruitment process lacked a prescribed minimum benchmark of suitability, resulting in candidates with virtually no merit being selected. Justice Sharma emphasized that public employment must uphold institutional integrity and administrative efficiency, and the selection of candidates with negligible marks undermines these principles.
Citing previous Supreme Court judgments, the court reiterated that reservation in public employment must not compromise minimum standards of suitability and efficiency. The judgment directed the State Government to frame guidelines within three months to ensure the prescription of minimum qualifying marks in future recruitments.
The quashed recruitment list included categories such as General-Ex-serviceman, SC-Widow, ST-Widow, and others, where selected candidates had secured marks that were deemed below rational standards of suitability. The court ordered a fresh exercise to prepare a merit/select list for these categories, adhering to constitutional requirements.
This judgment is expected to have significant implications on future recruitment processes, ensuring that public employment maintains a balance between reservation policies and minimum standards of competence.
Bottom line:-
Recruitment process - Selection of candidates securing negative or negligible marks through normalisation process is arbitrary and violative of Articles 14 and 16 of the Constitution. Minimum qualifying standards in public employment must be prescribed to maintain institutional integrity and administrative efficiency.
Statutory provision(s): Articles 14, 16, 335 of the Constitution of India
Vinod Kumar v. State of Rajasthan, (Rajasthan)(Jaipur Bench) : Law Finder Doc id # 2905499
