Supreme Court Sets Aside Madhya Pradesh High Court's Review on Judicial Recruitment Process

High Court's directive to re-compute cut-off marks and hold fresh examination deemed impermissible under review jurisdiction

In a significant ruling, the Supreme Court of India has overturned a decision by the Madhya Pradesh High Court that sought to re-evaluate the recruitment process for Civil Judge (Entry Level) under the Madhya Pradesh Judicial Service Rules, 1994. The apex court criticized the High Court for overstepping its review jurisdiction by ordering the re-computation of cut-off marks and directing a fresh main examination.

The case, titled High Court of Madhya Pradesh v. Jyotsna Dohalia, revolved around the exercise of review jurisdiction by the Madhya Pradesh High Court, which recalled its earlier order dismissing a writ petition regarding the recruitment process. The High Court had directed the exclusion of ineligible candidates from the preliminary examination held on January 14, 2024, and insisted on re-computing the cut-off marks by applying a 1:10 ratio, as well as conducting a fresh main examination.

The Supreme Court, led by Justices Pamidighantam Sri Narasimha and Atul S. Chandurkar, stated that the High Court's actions were beyond the scope of review jurisdiction, which is distinct from appellate jurisdiction. Review jurisdiction, the court noted, cannot be used to reconsider contentions already rejected, nor can it be employed to alter the recruitment process by re-computing cut-off marks.

The apex court emphasized that the apprehensions regarding the participation of ineligible candidates were unfounded and that the recruitment process should proceed according to the original cut-off marks. The Supreme Court also pointed out that the conduct of a second main examination for physically impaired candidates was unrelated to the current case and did not justify a third main examination.

The Supreme Court's judgment underscores the boundaries of review jurisdiction and reinforces the importance of adherence to established procedures in recruitment processes. The ruling ensures the continuation of the recruitment process as originally planned, thereby upholding the integrity of the judicial service recruitment under the Madhya Pradesh Judicial Service Rules, 1994.

Statutory provision(s): Civil Procedure Code, 1908 - Order 47 Rule 1, Madhya Pradesh Judicial Service Rules, 1994

High Court of Madhya Pradesh v. Jyotsna Dohalia, (SC) : Law Finder Doc Id # 2782749