Case Note & Summary
The appeals arose from a dispute concerning the appointment of the First Registrar of Rajiv Gandhi National Aviation University, established under the Rajiv Gandhi National Aviation University Act, 2013. The Central Government, in exercise of powers under Section 27(1) of the Act, framed the First Statute, 2016, which prescribed qualifications for the post of Registrar, including 'experience in educational administration'. The University issued an advertisement inviting applications, and the Selection Committee recommended Jitendra Singh (Respondent No.1) for the post. The Central Government approved the appointment, interpreting that his experience as Deputy Registrar in another university satisfied the eligibility requirement. A Single Judge of the High Court allowed a writ petition challenging the appointment, holding that the candidate lacked the requisite experience. The Division Bench dismissed the University's appeal. The Supreme Court, allowing the appeals, held that the High Court exceeded its jurisdiction by substituting its own interpretation of the eligibility criteria. The Court emphasized that the appointing authority's interpretation was plausible and not arbitrary, and judicial review in such matters is limited. The Supreme Court set aside the High Court's orders and restored the appointment of the First Registrar.
Headnote
A) Service Law - Appointment - Eligibility Criteria - Section 27(1) Rajiv Gandhi National Aviation University Act, 2013 - The issue pertained to the appointment of the First Registrar of the University - The Central Government, as the appointing authority, interpreted the eligibility requirement of 'experience in educational administration' to include experience as a Deputy Registrar in a university - The High Court set aside this interpretation and held that the candidate lacked the requisite experience - The Supreme Court held that the High Court exceeded its jurisdiction by substituting its own view on eligibility, as the interpretation by the appointing authority was plausible and not arbitrary - Held that the High Court's interference was unwarranted (Paras 10-15).
Issue of Consideration
Whether the High Court exceeded its jurisdiction by substituting its own view on the eligibility of a candidate for the post of Registrar, contrary to the decision of the statutory appointing authority under Section 27(1) of the Rajiv Gandhi National Aviation University Act, 2013.
Final Decision
The Supreme Court allowed the appeals, set aside the impugned order of the Division Bench dated 22.05.2024, and restored the order of the Deputy Secretary, Ministry of Civil Aviation dated 27.04.2022 appointing the First Registrar.
Law Points
- Interpretation of Section 27(1) of Rajiv Gandhi National Aviation University Act
- 2013
- Scope of judicial review in appointment matters
- Distinction between eligibility and selection criteria
