Case Note & Summary
The dispute arose from the selection process for police constables in Bihar, where the appellants were dismissed from service due to alleged manipulation of their height records. The minimum height requirement was set at 1.65 meters for general candidates and 1.60 meters for scheduled castes, which the appellants met. However, they were rejected based on the sole criterion of height, which the court found arbitrary and violative of Article 14 of the Constitution of India. The appellants had initially been selected based on their height exceeding that of the last selected candidates in their respective categories. After an inquiry revealed discrepancies in height measurements, they were dismissed. The High Court's decision to uphold their dismissal was contested, leading to this appeal. The appellants argued that their termination was unjust, especially since they were not responsible for the erroneous height records. The State defended the dismissal, citing the need for integrity in the selection process. The Supreme Court, while acknowledging the manipulation, deemed the termination after four years of service as excessively punitive. The court noted that the State had revised its recruitment rules to include additional criteria beyond height, indicating a shift in policy. Ultimately, the court allowed the appeal, directing that the appellants be given fresh appointments as constables against available vacancies within three months, without back wages or continuity of service. The decision underscored the importance of fair employment practices and the need for multiple selection criteria in recruitment processes.
Headnote
A) Constitutional Law - Equal Protection - Arbitrary Selection Criteria - Constitution of India, Article 14 - The court held that height cannot be the sole criterion for selection of police constables, as it violates the principle of equality. The revised recruitment rules indicated that the State acknowledged the need for additional criteria beyond height, rendering the previous selection method arbitrary (Paras 2-6). B) Employment Law - Termination of Service - Grounds for Dismissal - Not mentioned - The court found that while the appellants were accused of manipulation in height measurement, their termination after four years of service was too harsh. The court directed fresh appointments against available vacancies, emphasizing the need for fairness in employment practices (Paras 12-13).
Issue of Consideration
Whether the appellants, who had the prescribed minimum height, could be terminated from service based on alleged manipulation of height records.
Final Decision
The Supreme Court allowed the appeal, directing that the appellants be given fresh appointments as constables against available vacancies within three months, without back wages or continuity of service.
Law Points
- Selection criteria
- height requirement
- arbitrary dismissal
- constitutional validity
- recruitment rules
