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2025 Supreme(Mad) 2580

IN THE HIGH COURT OF JUDICATURE AT MADRAS 
C.V. KARTHIKEYAN, J.
Dr.Saravana Kumar M - Appellant 
Vs.
Government of Tamil Nadu - Respondent 
W.P.Nos.10788, 10795, 10799, 10908 & 11182 of 2025 And W.M.P.Nos.12144, 12146, 12147, 12153, 12155, 12157, 12162, 12164, 12168, 12309, 12310, 11313, 12610, 12613 & 12616 of 2025 
Decided On : 01-04-2025 


Advocates:
Advocate Appeared:
For the Appellant : Mr. M.Velmurugan
For the Respondent:Mr.J.Ravindran Additional Advocate General Assisted by Mr.L.Murugavelu, Mr.J.Selvaraja, Mr.U.Baranidharan

Eligibility for recruitment must be determined by the last date for applications, and late qualifications do not grant a right to selection or appointment.

Headnote:(A) Recruitment Process Regulations - Mandate for candidates to fulfill eligibility criteria and register with the relevant medical council before a specified cut-off date - The applicants failed to secure registration before the deadline of 15.07.2024 outlined in the Notification. (Paras 15-17, 29-30)

(B) Judicial Review Limitations - Judicial discretion cannot be exercised to extend cut-off dates post-selection process completion, as it undermines fairness and transparency in recruitment. (Paras 24-35)

(C) Precedent and Compliance - Past rulings reinforce that eligibility must be assessed by the cut-off date, and failing to meet this disqualifies candidates irrespective of later qualification. (Paras 19-21)

Facts of the case:
The writ petitioners applied for the Assistant Surgeon (General) position, alleging exclusion from the selection list due to registration delays with the Tamil Nadu Medical Council. They claimed the inability to register before the cut-off date resulted from system congestion and issued provisional certificates.

Findings of Court:
The court affirmed that the selection adhered to the stipulated regulations, emphasizing that candidates must have met qualification requirements by the last date of application. The failure to secure registration before the cut-off renders their claims ineligible.

Issues: The court addressed whether the applicants were unfairly excluded from the selection despite completion of qualifications and if the cut-off date could be extended under compassionate grounds.

Ratio Decidendi: The court upheld that eligibility is strictly tied to the cut-off date of 15.07.2024, rejecting claims for leniency based on administrative delays, thus maintaining the integrity of the recruitment process.

Result: Writ petitions dismissed.

Table of Content
1. writ petitions regarding assistant surgeon post. (Para 1 , 2)
2. qualified candidates applied for registration. (Para 4 , 5 , 6)
3. final dismissal of writ petitions. (Para 7)
4. arguments on registration delays and grievances. (Para 8)

ORDER :

C.V. KARTHIKEYAN, J.

The writ petitioners had applied for the post of Assistant Surgeon (General).

2. All these Writ Petitions have been filed seeking records relating to the selection list issued consequent to Notification No.01/MRB/2024, dated 15.03.2024 with specific reference to Clause 6B(III) modified by Notification dated 14.05.2024 and to quash the same so far as the non-inclusion of these writ petitioners are concerned.

3. All the writ petitioners have raised the same ground questioning the Notification and therefore, a common order is passed with respect to these writ petitions.

4. All the writ petitioners were duly qualified to apply for the post of Assistant Surgeon (General). They had completed their Bachelor of Medicine and Bachelor of Surgery (M.B.B.S.) degree. Thereafter, they were issued with provisional certificate. Thereafter, they also completed their one year internship programme. On completion of internship, they were issued with provisional certificate-II. After receiving that particular certificate, they had applied with the third respondent for registration as registered Medical Practitioner.

5. The following are the details as to the date on which the petitioners applied for permanent Registration with the Tamil Nadu Medical Council / third respondent and the date on which the approval was granted and the time slot chosen by the writ petitioners and the date on which the certificates were verified for permanent registration.

S. No .W.P.No.PetitionerDate of Application for permanent registrationTNMCTime slot chosen by the petitionerCertificate verification for permanent registration
1.10788 of 2025Dr.Saravana Kumar M18.07.2024 08.14 pm19.07.2024 02.33 pm31.07.2024 11.00 am31.07.2024 10.33 am
2.10795 of 2025Dr.Saravana Kumar R18.07.2024 08.14 pm19.07.2024 02.33 pm31.07.2024 11.00 am31.07.2024 10.33 am
3.10799 of 2025Dr.Swetha Marimuthu24.07.2024 01.05 pm25.07.2024 03.44 pm31.07.2024 12.00 pm31.07.2024 11.08 am
4.10908 of 2025Dr.Sujith Raj S18.07.2024 06.57 pm22.07.2024 10.39 am01.08.2024 10.00 am01.08.2024 10.08 am
5.11182 of 2025Dr.Vignesh P.B 19.07.202407.27 pm22.07.2024 04.48 pm30.07.2024 12.00 pm30.07.2024 11.33 am

6. This Court had occasion to examine similar batch of writ petitions in W.P.No. 6533 of 2025 etc batch [ Dr.M.Sai Ghanesh Vs. Government of Tamil Nadu, represented by its Secretary, Medical Services Recruitment Board, Chennai and others , wherein this Court had passed the following common order:-

“9. The uniform arguments that have been advanced by the learned counsel in all the three Writ Petitions is that the Provisional Certificate -II, which was issued by Dr.M.G.R.Medical University, was issued only on 11.07.2024. It had been contended that these three writ petitioners had completed the course in the College, which runs for about five years in the year

2023 and had been issued with what is called as Provisional Certificate - I. But that is not sufficient. They have to undergo the Internship for a period of one year, which they have successfully completed. The learned counsels pointed out that thereafter, the Provisional Certificate-II had been issued by the University, which was the certificate certifying that they have undergone the course in the College and also successfully completed their Internship as required for a further period of one year. It is uniformly contended that this particular certificate/Provisional Certificate-II was issued only on 11.07.2024. The learned counsels pointed out that all the three writ petitioners had applied for the post of Assistant Surgeon (General) and they were also permitted to write the examinations and that therefore, they had a legitimate expectation that there could be no further hurdles while consid

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