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2026 Supreme(SC) 709
SUPREME COURT OF INDIA
J.K. MAHESHWARI, ATUL S. CHANDURKAR, JJ.
S. Senthil Kumaran Bose – Appellant
Versus
The State of Tamil Nadu And Others – Respondents
Civil Appeal No. 8626 of 2026 (@ SLP (C) No. 7906 of 2024)
With
N. Vaithi And Others – Appellant
Versus
The Secretary, The Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal Nos. 8627-8628 of 2026 (@ SLP (C) Nos. 12856-57 of 2024)
M. Mohammed Adhil – Appellant
Versus
The State of Tamil Nadu And Others – Respondents
Civil Appeal No. 8629 of 2026 (@ SLP (C) No. 7940 of 2024)
S. Dinesh Kumar – Appellant
Versus
The Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal No. 8630 of 2026 (@ SLP (C) No. 12475 of 2024)
G. Ramkumar – Appellant
VERSUS
The Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal No. 8631 of 2026 (@ SLP (C) No. 12474 of 2024)
P. Karthic And Others – Appellant
Versus
Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal No. 8632 of 2026 (@ SLP (C) No. 12472 of 2024)
J. Saranya And Others – Appellant
VERSUS
The Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal No. 8633 of 2026 (@ SLP (C) No. 12855 of 2024)
U. Omezhilan And Others – Appellants
VERSUS
The Tamil Nadu Public Service Commission And Others – Respondents
Civil Appeal No. 8634 of 2026 (@ SLP (C) No. 20487 of 2024)
And
The Tamil Nadu Public Service Commission And Others – Appellants
Versus
P. Satheesh Prabu And Others – Respondents
Civil Appeal Nos. 8635-8636 of 2026 (@ SLP (C) Nos. 8880-81 of 2026)
Decided On : 15-06-2026
For the Petitioner(s):Mr. C. Paramsivam, Adv. Mr. Ravindra Srivastava, Sr. Adv. Mr. Nishant Sharma, Adv. Mr. C. Paramasivam, Adv. Ms. Adviteeya, Adv. Mr. Rakesh K. Sharma, AOR Mr. Boudhik Garg, Adv. Ms. Shruti Verma, Adv. Mr. Atharv Joshi, Adv. Ms. Kavya Verma, Adv. Ms. Khushi Rastogi, Adv. Mr. S. Nagamuthu, Sr. Adv. Mr. M.p. Parthiban, AOR Ms. Priyaranjani Nagamuthu, Adv. Mr. Bilal Mansoor, Adv. Mr. Shreyas Kaushal, Adv. Mr. Balram Nayak, Adv. Mr. S. Geyolin Selvam, Adv. Mr. Alagiri K, Adv. Mr. Shivansh Sharma, Adv. Mr. Abhishek S, Adv. Ms. G. Indira, AOR Ms. Uttara Babbar, Sr. Adv. Mr. Km Vignesh Ram, Adv. Mr. Manoj V George, Adv. Ms. Akshita Agrawal, Adv. Mr. Ayush Shah, Adv. Ms. Ryana Mukherjee, Adv. Mr. Naveen Raj R, Adv. Mr. Nasib Masih, Adv. Mr. Azeem Samuel, Adv. Ms. Shilpa Liza George, AOR Mr. Bharathimohan M., Adv. Mr. Gokulakrisnan, Adv. Ms. V. Swetha, Adv. Mr. Raghunatha Sethupathy B, AOR
For the Respondent(s): Mr. N Subramaniyan, Adv. Ms. Neha Rathi, AOR Ms. Kajal Giri, Adv. Ms. Mishra Divya Santosh, Adv. Ms. Khushboo Singhal, Adv. Ms. Somya Kumari, Adv. Ms. Menaka Guruswamy, Sr. Adv. Mr. Pranav Sachdeva, AOR Mr. P Rohit Ram, Adv. Ms. Shaswati Parhi, Adv. Mr. Sanyam Jain, Adv. Mr. Sabarish Subramanian, AOR Ms. G. Indira, AOR Mr. Sanjay Kumar Visen, AOR Mr. Sandeep Singh, AOR Mr. Vikas Mehta, AOR Ms. Menaka Guruswamy, Sr. Adv. Mr. Pranav Sachdeva, AOR Mr. P Rohit Ram, Adv. Ms. Shaswati Parhi, Adv. Mr. Sanyam Jain, Adv. Mr. D. Sathiya, Adv. Mr. Mardiv Deslwa, Adv. Mr. Hitesh Kumar Sharma, Adv. Mr. Vairawan A.S, AOR
Transparency in recruitment requires equitable verification of credentials and, in the interest of public accountability, mandates that performance metrics be accessible. Administrative procedures must be uniform to prevent arbitrary exclusion of candidates, ensuring that eligibility based on specialized learning and experience is properly recognized.
Headnote:(A) Service Law - Recruitment - Verification of credentials - Experience certificates - Where administrative policies regarding the retroactive approval of vocational workshops lacked uniformity, leading to potential exclusion, the court may mandate a comprehensive re-verification of experience credentials to ensure parity among all candidates. (Paras 10, 11, 16)
(B) Service Law - Selection process - Transparency - Right to information - Public interest justifies directing authorities to disclose performance scores of candidates who fall outside the immediate zone of consideration to maintain accountability, provided such disclosure does not include sensitive examination materials like answer sheets. (Paras 20, 22)
(C) Service Law - Eligibility - Specialized education quotas - Certificates issued by the head of an academic institution confirming the mode of instruction are sufficient to establish eligibility for specialized education quotas in the absence of more stringent, prescribed administrative requirements. (Paras 19, 21)
Facts of the case:
Direct recruitment for government technical posts faced multiple rounds of judicial challenge concerning the validity of prerequisite work experience and eligibility for education-based quotas. Conflicting interpretations of administrative approvals for vocational training centers and the sufficiency of academic records led to multiple rounds of re-assessment. Aggrieved candidates and recruiting authorities sought clarity on the finality of select lists and the obligation to disclose performance metrics.
Findings of Court:
Upon re-verification, it was held that candidates who possessed the requisite experience following a retroactive review of workshop approvals must be considered. The court affirmed that certificates from educational heads regarding language of instruction are binding criteria. Furthermore, the court determined that public interest dictates the disclosure of marks for all participants in a transparent selection process.
Issues: The primary issues concerned the sufficiency of work experience documentation, the legality of administrative discretion in granting retroactive approvals, the evidentiary standards for special education quotas, and the extent of mandatory disclosure of performance results for candidates remaining outside the designated selection zone.
Ratio Decidendi: Ensuring a level playing field for all applicants is the hallmark of a fair recruitment process. When administrative irregularities or lack of clear policy prevent qualified candidates from assessment, judicial intervention for re-verification is permissible. Additionally, in the interest of transparency and to mitigate prolonged litigation, disclosure of performance outcomes is deemed a necessary public requirement.
Result: Appeals disposed of.
| Table of Content |
|---|
| 1. procedural history and factual background of the recruitment litigation. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 9) |
| 2. verification of work experience certificates and validity of retrospective approvals for workshops. (Para 8 , 10 , 11 , 12 , 13) |
| 3. judicial review of selection processes and maintenance of a level playing field for candidates. (Para 14 , 15 , 16 , 17) |
| 4. validity of tamil medium (pstm) quota certificates and public interest disclosure of candidate marks. (Para 18 , 19 , 20 , 21 , 22 , 23) |
JUDGMENT :
ATUL S. CHANDURKAR, J
1. Leave granted.
2. Applications for impleadment are allowed.
3. Recruitment on 113 posts of Motor Vehicle Inspector-Grade II by the Tamil Nadu Public Service Commission1[For short, ‘the TNPSC’] pursuant to Notification dated 14.02.2018 has been embroiled in litigation. The Madras High Court by its impugned judgment having directed a fresh exercise to be undertaken by the official respondents, aggrieved candidates and the TNPSC have come up in appeal.
4. By Notification No.3/2018 dated 14.02.2018 issued by the TNPSC, 113 posts of Motor Vehicle Inspector-Grade II were sought to be filled through direct recruitment. The recruitment was undertaken by the Tamil Nadu Transport Subordinate Services. The selection was to be undertaken in three stages. Firstly, a written examination of all candidates was to be conducted. Thereafter, verification of their certificates and documents was to be done followed by oral interview of the candidates. Initially the TNPSC received 2176 applications from interested candidates. After initial screening, 1328 candidates were permitted to appear in the written examination. 33 candidates passed in the written examination. A list to that effect was accordingly published on 15.07.2019. One of the candidates indicated his disinclination to participate in the further process of recruitment. Accordingly, 32 candidates came to be provisionally selected and on 04.11.2019 appointment orders were issued to them. The selection of the said 32 candidates for interview was the subject matter of challenge in various writ petitions before the Madras High Court. By common judgment dated 24.01.2020, a learned Single Judge set aside the appointment of the 32 candidates. A fresh verification of the workshop experience certificates of all 1328 candidates was directed to be undertaken. It was clarified that the experience of one year as required would be satisfied if a candidate had worked for at least 240 days in a given year. Consequently, the list of 32 candidates that had been published earlier was effaced.
5. The parties aggrieved by the aforesaid judgment preferred writ appeals before the Division Bench. After hearing the concerned parties, the Division Bench partly allowed the writ appeals and upheld all the directions issued by the learned Single Judge except Direction No.44(g). A verification of work experience certificates, validity of driving license and driving experience certificates as per Clause 10 of the advertisement was directed to be carried out. A list of candidates in the ratio of 1:2 was to be drawn after which the candidates were to undergo an oral test.
This order passed by the Division Bench was challenged before this Court in K. Ilavarasan and others Vs. R. Vijiyaraj and others , SLP (C) No. 13571 of 2020. The said proceedings, however, were dismissed on 19.01.2021.
6. The process of selection was again undertaken and on the basis of marks obtained in the written examination, a list of 226 candidates was published by the TNPSC on 28.04.2021 and they were called for oral test. Being aggrieved by the said list, aggrieved candidates again approached the High Court by filing separate writ petitions. A learned Single Judge decided the said writ petitions vide common order dated 10.02.2023. Various issues that arose for consideration were divided into XI batches alongwith other miscellaneous issues. In conclusion, the learned Single Judge directed the TNPSC to compl
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