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2025 Supreme(Mad) 2944

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.V. KARTHIKEYAN, J.
Dr.Nandhini R - Appellant 
Versus 
Government of Tamil Nadu - Respondent  
W.P.Nos.8804, 8807, 8810, 8814 & 8816 of 2025 and  W.M.P.Nos.9866, 9868, 9874, 9875, 9877, 9878, 9883, 9884, 9887, 9888 of 2025
Decided on : 24-03-2025

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, Ms.C.Latharani, Mr.U.Bharanidharan

Eligibility for public employment is determined strictly as of the cut-off date specified in recruitment notifications, and late fulfillments do not confer a right to be considered.

Headnote:(A) Tamil Nadu Medical Council Act, 1958 - Selection criteria for Assistant Surgeon (General) - Candidates must register with Tamil Nadu Medical Council on or before cut-off date stipulated in notification - Provisional Certificate-II issued after cut-off does not confer eligibility - Court found no reasons to deviate from established precedent that eligibility is assessed as of last application date (Paras 11, 13, 19, 30).

(B) Legitimacy of selection process - Court emphasized transparent, non-arbitrary criteria should govern recruitment; no exceptions may be made for individual candidates (Paras 24, 30).

(C) Legal principles from Supreme Court rulings reinforcing eligibility must be assessed by last date of application (Paras 20-22, 29).

Facts of the case:
The writ petitioners sought inclusion in selection for Assistant Surgeon (General) post, contesting disqualification due to late registration with Tamil Nadu Medical Council following the last date outlined in the notification. Court noted that all petitioners claimed registration after 15.07.2024, violating eligibility criteria.

Findings of Court:
The court found that uniform adherence to registration deadlines is paramount to ensure fairness in the selection process.

Issues: Whether the petitioners' late registration justified their inclusion in the selection process and the implications of their arguments regarding inability to comply with the registration timeline.

Ratio Decidendi: The court ruled that sympathy cannot override established eligibility requirements for recruitment, affirming that late registration disqualifies candidates from selection.

Result: Writ Petitions dismissed.

Table of Content
1. factual background of the case. (Para 1 , 2 , 3 , 4 , 5)
2. arguments concerning eligibility and selection criteria. (Para 6)
3. conclusion on dismissal of writ petitions. (Para 8)

ORDER :

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 registrationTNMC ApprovalTime slot chosen by the petitionerCertificate verification for permanent registration
1.8804/2025Dr.Nandhini R19.07.2024 07.25 pm22.07.2024 04.40 pm30.07.2024 12.00 pm30.07.2024 11.36 pm
2.8807/2025Dr.Sneha S20.07.2024 11.25 am23.07.2024 04.11 pm29.07.2024 03.00 pm29.07.2024 03.22 pm
3.8810/2025Dr.K.Sakthivel21.07.2024 12.31 pm22.07.2024 09.37 am25.07.2024 03.00 pm25.07.2024 02.40 pm
4.8814/2025Dr.E.Karthik Kumar18.07.2024 06.24 pm19.07.2024 10.42 pm24.07.2024 03.00 pm24.07.2024 11.23 am
5.8816/2025Dr.Shakina20.07.2024 10.51 am23.07.2024 04.09 pm30.07.2024 11.00 am30.07.2024 11.26 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 considering their selection or on examining their credentials vis-a-vis the applications, which they had submitted. B



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