Case Note & Summary
The Teachers Recruitment Board (Board) issued a notification on 28.07.2017 inviting applications for 1058 Lecturer posts in Government Polytechnic Colleges in Tamil Nadu. A written examination was conducted on 16.09.2017, and the merit list for certificate verification was released on 07.11.2017. Complaints of malpractices led to an internal inquiry, revealing manipulation of OMR answer sheets benefiting 196 candidates. The Board cancelled the entire examination and withdrew the merit list on 11.12.2017, and lodged a criminal complaint. Writ petitions were filed in the Madras High Court. A Single Judge of the Madurai Bench allowed the petition, directing segregation of tainted candidates. Another Single Judge of the Principal Bench dismissed similar petitions, upholding the cancellation. Appeals were decided by a Division Bench, which ruled in favor of the candidates, holding that segregation was possible and the entire cancellation was vitiated. The State and Board appealed to the Supreme Court. The Supreme Court allowed the appeals, setting aside the Division Bench's order. The Court held that the Board's decision to cancel the entire examination was bona fide, based on abundant material indicating large-scale malpractices, and the High Court erred in interfering. The Court distinguished the precedent in Inderpreet Singh Kahlon, noting that the facts were different. The Supreme Court restored the order of the Single Judge of the Principal Bench, upholding the cancellation of the examination.
Headnote
A) Service Law - Recruitment - Cancellation of Examination - Malpractices - Teachers Recruitment Board, Tamil Nadu - The Board cancelled the entire written examination after discovering manipulation of OMR answer sheets benefiting 196 candidates, with possibility of more malpractices. The Supreme Court held that the Board's decision was bona fide and aimed at maintaining integrity, and the High Court ought not to have interfered. (Paras 1-13) B) Judicial Review - Administrative Decision - Scope - The Court held that sufficiency of material for cancellation is not within the purview of the High Court; the decision was based on abundant material and was not arbitrary. (Paras 10-13) C) Precedent - Distinguishing - Inderpreet Singh Kahlon v. State of Punjab - The facts of that case were different as it involved termination of services after appointment, whereas the present case involved cancellation of examination prior to selection. (Para 12)
Issue of Consideration
Whether the cancellation of the entire written examination for the post of Lecturers in Government Polytechnic Colleges by the Teachers Recruitment Board was justified in light of malpractices involving manipulation of OMR answer sheets, and whether the High Court erred in interfering with such decision.
Final Decision
The Supreme Court allowed the appeals, set aside the judgment of the Division Bench of the Madras High Court, and restored the order of the learned Single Judge of the Principal Bench which upheld the cancellation of the written examination. The Court held that the Board's decision to cancel the entire examination was bona fide and based on sufficient material, and the High Court erred in interfering.
Law Points
- Cancellation of examination due to malpractices
- Segregation of tainted candidates
- Scope of judicial review in administrative decisions
- Bona fide decision of examining body
