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2025 Supreme(Mad) 3221

IN THE HIGH COURT OF JUDICATURE AT MADRAS
C.V. KARTHIKEYAN, J.
Dr. Ukesh & Ors. - Petitioners
Versus
Government of Tamil Nadu, Represented by its Member Secretary, Medical Services Recruitment Board, Teynampet, Chennai & Ors. - Respondents
W.P.Nos.7107, 7121, 7128, 7130 & 7135 of 2025 And W.M.P.Nos.7864, 7865, 7892, 7894, 7904, 7905, 7910, 7911, 7914 & 7915 of 2025
Decided On : 06-03-2025

Advocates Appeared:
For the Petitioners in all W.Ps.: Mr. A. Durai Eswar.
For the Respondents in all W.Ps.:Mr. J. Ravindran Additional Advocate General Assisted by Mr. L. Murugavelu, Mr. G. Arumugam, Mr. U. Bharanidharan.

The eligibility of candidates for selection must be assessed as of the specified cut-off date, and compliance with notification requirements is mandatory.

Headnote:(A) Recruitment Process - Eligibility Criteria - Notification No.01/MRB/2024 - Amendment Notification dated 14.05.2024 - Selection process for Assistant Surgeon (General) - Writ Petitioners, though qualified, registered post cut-off date for selection, consequently ineligible - Importance of adherence to stipulated cut-off dates emphasized - Recruitment rules not to be flexibly interpreted or altered post-notification - Principle of legitimate expectation does not excuse non-compliance with established deadlines. (Paras 6, 17, 27)

(B) Judicial Review - Court's role in recruitment processes - Courts must refrain from interfering with criteria established in recruitment notifications - Caveat against exercising compassion or sympathy in cases where procedural adherence is lacking - Importance of maintaining integrity in recruitment processes highlighted. (Paras 23, 24)

Facts of the case:
Petitioners applied for Assistant Surgeon (General) position but failed to register with the Tamil Nadu Medical Council by the stipulated cut-off of 15.07.2024, citing system congestion as a reason for delay.

Findings of Court:
Dismissal of writ petitions upholding that failure to register by the deadline results in disqualification, affirming that eligibility must be assessed as per terms of the recruitment notification.

Issues: Core question centered on whether registration post cut-off can justify consideration for selection despite meeting the qualifications.

Ratio Decidendi: The court reinforced the principle that the eligibility of candidates is determined as of the cut-off date specified in the recruitment notification, asserting that registration delays do not warrant exceptions.

Result: Writ Petitions dismissed.

Table of Content
1. background of writ petitions and qualifications (Para 1 , 2 , 3 , 4 , 5)
2. arguments regarding eligibility and registration issues (Para 6)
3. conclusion of case and dismissal of petitions (Para 7 , 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 registrationTNMCTime slot chosen by the petitionerCertificate verification for permanent registration
1.7107/2025Dr.Ukesh K13.07.2024 10.49 am13.07.2024 03.13 pm18.07.2024 12.00 pm18.07.2024 11.28 am
2.7128/2025Dr.Pramod D12.07.2024 01.50 pm13.07.2024 12.34 pm19.07.2024 12.00 pm19.07.2024 10.42 am
3.7130/2025Dr.Pravinraj R16.07.2024 12.10 pm21.07.2024 07.17 pm16.08.2024 02.00 pm16.08.2024 01.22 pm
4.7135/2025Dr.Dinesh Prabu V14.07.2024 02.43 pm15.07.2024 04.13 pm22.07.2024 11.00 am22.07.2024 09.58 am
5.7121/2025Dr. Ruban Richard P12.07.2024 11.31 pm13.07.2024 10.41 am16.07.2024 12.00 pm16.07.2024 11.50 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, wh

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