Rajasthan HC upholds RPSC Veterinary Officer & Assistant Agriculture Officer recruitment shortlisting, says process valid

Jaipur: The Rajasthan High Court has held that where the procedure adopted by the recruiting authority is consistent with the governing rules and the terms of the advertisement, the same cannot be interfered with in exercise of writ jurisdiction merely on the ground of alleged comparative merit among candidates of different categories. The Court upheld the methodology adopted by the Rajasthan Public Service Commission (RPSC) for shortlisting candidates for interview and dismissed a batch of writ petitions challenging the recruitment process.

The judgment was delivered by Justice Anand Sharma in a batch of petitions led by S.B. Civil Writ Petition No. 14328/2020, Vishnu Datt Saini & Ors. vs State of Rajasthan & Ors., along with connected matters.

The petitions arose out of recruitment to the posts of Veterinary Officer and Assistant Agriculture Officer, wherein the petitioners had challenged the screening result dated November 26, 2020 and the shortlisting methodology adopted by RPSC for calling candidates for interview.

The primary contention of the petitioners was that the shortlisting of candidates in the ratio of 1:3 category-wise was arbitrary, as more meritorious candidates belonging to reserved categories were allegedly excluded while less meritorious candidates from the unreserved category were included, without allowing migration of reserved category candidates to the general category at the stage of screening.

The Court framed the core issue as to whether the action of RPSC in adopting category-wise shortlisting without inter se comparison across categories at the stage of screening examination was arbitrary or illegal so as to warrant interference under Article 226 of the Constitution.

At the outset, the Court noted that the recruitment process was governed by the Rajasthan Animal Husbandry Service Rules, 1963 and the Rajasthan Agriculture Subordinate Service Rules, 1978. It observed that under the Rules of 1963, the selection process essentially consists of a single stage, namely interview, and the screening test serves only as a mechanism for shortlisting candidates.

The Court further took note of the earlier round of litigation, wherein a Coordinate Bench had quashed the result dated November 26, 2020 on a limited ground relating to non-consideration of academic weightage marks. However, the said judgment was subsequently set aside by a Division Bench in intra-court appeals, which upheld the procedure adopted by RPSC and held that it was neither arbitrary nor contrary to the rules or advertisement.

Relying on the findings of the Division Bench, the Court reiterated that where the advertisement does not prescribe a specific sequence of stages in the selection process, the procedure adopted by the Commission cannot be termed arbitrary if it is otherwise consistent with the governing rules.

The Court also accepted the contention of the respondents that shortlisting category-wise in proportion to available vacancies is a recognised and reasonable method, and comparison between candidates of different categories at the stage of screening is misconceived.

On the issue of migration of reserved category candidates to the unreserved category at the stage of screening, the Court held that such a claim is contrary to settled legal principles and cannot be accepted at the stage of shortlisting.

The Court observed that the screening examination is only a preliminary step for shortlisting candidates and does not determine final merit. Therefore, any grievance regarding comparative merit across categories at this stage does not warrant judicial interference.

Upon analysis, the Court concluded that the methodology adopted by RPSC for shortlisting candidates for interview did not suffer from arbitrariness, illegality, or violation of statutory rules. It held that no case for interference under Article 226 was made out.

In conclusion, the Court held that the impugned screening result dated November 26, 2020 and the procedure adopted by RPSC for shortlisting candidates do not warrant interference, and the writ petitions being devoid of merit were accordingly dismissed.

Case Title
Vishnu Datt Saini & Ors. vs State of Rajasthan & Ors.

Case Number
S.B. Civil Writ Petition No. 14328/2020 (along with connected matters)

Court
High Court of Judicature for Rajasthan, Jaipur Bench

Bench
Justice Anand Sharma