Supreme Court Allows University's Appeal in Registrar Appointment Dispute — High Court Exceeded Jurisdiction Under Section 27(1) of Rajiv Gandhi National Aviation University Act, 2013. The Court held that the appointing authority's interpretation of 'experience in educational administration' was plausible and not arbitrary, and the High Court erred in substituting its own view.

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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).

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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.

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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
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Case Details

2026 LawText (SC) (01) 97

Civil Appeal No. of 2026 (@ SLP (C) No. 16265 of 2024) with Civil Appeal No. of 2026 (@ SLP (Civil) No. of 2026) (Diary No. 38863 of 2024)

2026-01-01

Alok Aradhe

2026 INSC 520

Vice Chancellor, Rajiv Gandhi National Aviation University

Jitendra Singh & Ors.

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Nature of Litigation

Civil appeals against the order of the High Court setting aside the appointment of the First Registrar of Rajiv Gandhi National Aviation University.

Remedy Sought

The appellant (University) sought to set aside the High Court's order and restore the appointment of the First Registrar.

Filing Reason

The High Court set aside the appointment of the First Registrar on the ground that he lacked the requisite experience in educational administration.

Previous Decisions

The Single Judge of the High Court allowed the writ petition challenging the appointment; the Division Bench dismissed the University's appeal.

Issues

Whether the High Court exceeded its jurisdiction by substituting its own interpretation of the eligibility criteria for the post of Registrar. Whether the appointing authority's interpretation of 'experience in educational administration' was arbitrary or unreasonable.

Submissions/Arguments

The appellant argued that the High Court erred in interfering with the appointment, as the appointing authority's interpretation was plausible and within its discretion. The respondent contended that the candidate lacked the requisite experience and the appointment was illegal.

Ratio Decidendi

The High Court exceeded its jurisdiction by substituting its own view on the eligibility of a candidate for appointment, where the appointing authority's interpretation of the eligibility criteria was plausible and not arbitrary. Judicial review in such matters is limited to examining whether the decision is arbitrary or unreasonable.

Judgment Excerpts

Leave granted. These appeals assail the order dated 22.05.2024 passed by the Division Bench of the High Court of Judicature at Allahabad, Lucknow Bench...

Procedural History

The Deputy Secretary, Ministry of Civil Aviation appointed the First Registrar on 27.04.2022. A writ petition was filed challenging the appointment, which was allowed by the Single Judge on 25.04.2023. The University's appeal to the Division Bench was dismissed on 22.05.2024. The University then appealed to the Supreme Court.

Acts & Sections

  • Rajiv Gandhi National Aviation University Act, 2013: Section 27(1)
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