Supreme Court Allows Appeal in Age Relaxation Case for Mukhya Sevika Appointment — Upholds Uniform Age Limit Application. Citing that no individual candidate can claim a vested right to age relaxation, the court emphasized the necessity of uniform eligibility criteria.

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Case Note & Summary

The appeal arose from a judgment of the High Court of Judicature at Allahabad concerning the claim of a respondent for age relaxation in the appointment to the post of Mukhya Sevika. The respondent, having crossed the age limit of 50 years, sought age relaxation based on her long service as an Anganwadi worker. The Single Judge of the High Court directed the State to consider her claim under the Uttar Pradesh Public Services (Relaxation of the Age limits for Recruitment) Rules, 1992. The State contended that the respondent was not a government employee and thus ineligible for the relaxation. The Single Judge accepted the claim, leading to a Special Appeal by the State, which was dismissed by the Division Bench of the High Court. The Supreme Court, upon review, noted that the State had uniformly applied the age limit and had considered the respondent's representation twice, ultimately denying the relaxation. The court emphasized that no individual candidate could claim a vested right to age relaxation, which lies within the discretion of the appointing authority. The court allowed the appeal, set aside the High Court's judgment, and dismissed the writ petition filed by the respondent.

Headnote

A) Administrative Law - Age Relaxation - Discretionary Power of State - Uttar Pradesh Public Services (Relaxation of the Age limits for Recruitment) Rules, 1992, Rule 3 - The court held that the respondent could not claim age relaxation as a matter of right, emphasizing that eligibility criteria must be uniformly applied to avoid arbitrary selections. The State's discretion in granting age relaxation was upheld (Paras 15-16).

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Issue of Consideration

Whether the Single Judge of the High Court was justified in directing the State to consider the claim of the respondent for the grant of an age relaxation in making appointments to the post of Mukhya Sevika.

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Final Decision

The Supreme Court allowed the appeal, set aside the High Court's judgment, and dismissed the writ petition filed by the respondent, affirming the uniform application of age limits.

Law Points

  • Age relaxation
  • recruitment rules
  • discretionary power
  • eligibility criteria
  • arbitrary selection
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Case Details

2022 LawText (SC) (08) 217

Civil Appeal No 5207 of 2022

2022-08-08

Dr Dhananjaya Y Chandrachud, A S Bopanna

Mr Tanmaya Agarwal, Mr Wrick Chatterjee

State of Uttar Pradesh and Others

Shanti Devi

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Nature of Litigation

Appeal against the High Court's judgment regarding age relaxation for recruitment.

Remedy Sought

The State of Uttar Pradesh sought to overturn the High Court's directive to grant age relaxation.

Filing Reason

The respondent claimed age relaxation based on long service as an Anganwadi worker.

Previous Decisions

The Single Judge's decision was affirmed by the Division Bench of the High Court.

Issues

Whether the respondent was entitled to age relaxation under the applicable rules Whether the State's discretion in applying age limits was justified

Submissions/Arguments

The appellant argued that the respondent was not a government employee and thus ineligible for age relaxation. The respondent contended that her long service warranted consideration for age relaxation.

Ratio Decidendi

The court held that age relaxation cannot be claimed as a matter of right and must be uniformly applied to avoid arbitrary selections, emphasizing the discretionary power of the appointing authority.

Judgment Excerpts

The claim of the petitioner for grant of age relaxation under the aforesaid rules appears to be justified. No individual candidate can claim a vested right to age relaxation which lies in the discretion of the appointing authority.

Procedural History

The Single Judge directed the State to consider the respondent's claim for age relaxation, which was affirmed by the Division Bench of the High Court. The State filed a Special Appeal against this decision, which was ultimately allowed by the Supreme Court.

Acts & Sections

  • Uttar Pradesh Public Services (Relaxation of the Age limits for Recruitment) Rules: Rule 3
  • Uttar Pradesh Child Development and Nutrition (Subordinate) Service Rules: Rule 5(4), Rule 15B
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