This case addresses whether recruitment authorities can change eligibility benchmarks or selection criteria after the recruitment process has started, specifically, imposing a minimum cutoff mark post-examination in the selection process for public posts. The case centers around the doctrine that "rules of the game" should not be changed mid-way or post-facto. The Court examined relevant precedents and determined that eligibility or procedural changes after the recruitment's commencement are generally impermissible, as they can prejudice candidates who relied on the initial criteria.

Acts and Sections Discussed

• Constitution of India: Articles 14 (Right to Equality), 16 (Equality of Opportunity in Public Employment), and 309 (Power to Regulate Recruitment for Public Services).
• Judicial Precedents: Interpretations in K. Manjusree v. State of A.P., Subash Chander Marwaha v. State of Haryana, and related cases regarding eligibility criteria and recruitment methods.

Ratio Decidendi:

1. Non-Retroactive Rule Changes: The Court affirmed that, in recruitment for public services, authorities should not alter eligibility criteria or minimum cut-off marks after the recruitment process has begun, as this would violate principles of fairness and transparency.
2. Legitimate Expectation and Fairness: Candidates have a legitimate expectation that recruitment processes, including benchmarks for selection, will remain consistent throughout. Altering these criteria post-facto is deemed arbitrary and contrary to Articles 14 and 16 of the Constitution.
3. Guidance for Public Authorities: While public authorities can establish selection procedures, any critical benchmarks or qualifying marks must be set at the outset and should not be altered once the recruitment process is in motion.

Introduction

• Para 1-2: Appeals involve interpretation of recruitment procedures for Translators in the Rajasthan High Court.
• Para 3: References legal issue of changing eligibility mid-process, seeking authoritative clarification from a larger Bench.

Factual Background

• Para 4-5: In 2009, Rajasthan High Court issued a recruitment notice but later imposed a 75% minimum cut-off after the exam.
• Para 6: The appellants challenged the cut-off imposition, arguing it constituted a “change of the game’s rules.”

Legal Precedents Discussed

• Para 10-12: Comparison with K. Manjusree and Subash Chander Marwaha; deliberation on retrospective changes.

Core Legal Issue

• Para 15-16: Whether the High Court’s mid-process criteria adjustment violated Articles 14 and 16 by creating a situation that seemed arbitrary.

Analysis by the Court

• Para 18-20: Assessment of K. Manjusree’s principle against changing criteria mid-recruitment as a foundation of fair recruitment practices.

Final Decision and Ratio

• Para 25-30: Establishes that recruitment authorities must maintain initial criteria, and any change must occur prior to initiating the selection process.

Subjects:

• Recruitment, Public Employment, Doctrine of Legitimate Expectation, Fair Process in Selection, Rule of Law in Administration
• Public Service Recruitment, Fairness in Recruitment Processes, Doctrine of “Rules of the Game.”