Case Note & Summary
The appellant, Manoj Goyal, an advocate aspiring to be appointed as an Additional District Judge in Rajasthan, challenged the constitutional validity of Rule 41 of the Rajasthan Judicial Service Rules, 2010, specifically the proviso inserted on 10.06.2011 which mandated a minimum qualifying benchmark of 25% marks in the viva-voce (interview) for candidates from the advocates' quota. The appellant had participated in the selection process but was unsuccessful. He filed a writ petition before the Rajasthan High Court, which dismissed it on 08.02.2018, holding that the challenge had become academic due to subsequent amendments to the Rules and that the appointments already made should not be disturbed. Aggrieved, the appellant appealed to the Supreme Court. The Supreme Court examined the validity of the rule and held that prescribing a minimum qualifying mark in the interview is a policy decision within the rule-making power of the High Court under Article 233 of the Constitution. The Court noted that the Shetty Commission had recommended such benchmarks to ensure selection of suitable candidates. The Court found no arbitrariness or violation of Article 14, as the classification was reasonable and had a nexus with the object of selecting meritorious judicial officers. The Court also observed that the challenge had become academic because the rule was subsequently amended, and the appointments made were not interfered with. Consequently, the Supreme Court dismissed the appeal, upholding the High Court's judgment.
Headnote
A) Service Law - Judicial Appointments - Minimum Qualifying Marks in Viva-Voce - Constitutional Validity - Rule 41 of Rajasthan Judicial Service Rules, 2010 - The challenge was to the proviso inserted vide notification dated 10.06.2011 requiring 25% minimum marks in interview for District Judge (Direct Recruitment) from advocates' quota. The Supreme Court held that prescribing a minimum benchmark in viva-voce is a policy decision within the rule-making power and not arbitrary. The challenge became academic as the rule was subsequently amended. (Paras 3, 6-8) B) Constitutional Law - Article 14 - Reasonable Classification - Rule 41 of Rajasthan Judicial Service Rules, 2010 - The Court held that the classification between candidates based on interview performance is reasonable and has a nexus with the object of selecting meritorious judicial officers. The minimum qualifying marks ensure that candidates possess the requisite personality and aptitude for judicial office. (Paras 6-8) C) Service Law - Recruitment Rules - Judicial Review - Scope - The Court reiterated that courts should not interfere with recruitment rules unless they are manifestly arbitrary or violative of constitutional provisions. The rule in question was a valid exercise of power under Article 233 of the Constitution. (Paras 6-8)
Issue of Consideration
Whether the proviso to Rule 41 of the Rajasthan Judicial Service Rules, 2010, mandating a minimum qualifying benchmark of 25% marks in the viva-voce (interview) for appointment to the District Judge cadre from the advocates' quota, is constitutionally valid and not arbitrary.
Final Decision
The Supreme Court dismissed the appeal, upholding the judgment of the Rajasthan High Court. The Court held that the challenge to Rule 41 had become academic due to subsequent amendments and that the rule was not arbitrary or unconstitutional.
Law Points
- Constitutional validity of Rule 41 of Rajasthan Judicial Service Rules
- 2010
- Minimum qualifying marks in viva-voce
- Judicial appointments from advocates' quota
- Scope of judicial review of recruitment rules
- Doctrine of academic challenge
