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2026 Supreme(Del) 645

IN THE HIGH COURT OF DELHI AT NEW DELHI
Sanjeev Narula, J.
Rajat Kumar Singh - Petitioner
Versus 
Union Of India & Ors - Respondent
W.P.(C) 7371 of 2019 & CM APPL. 30729 of 2019
Decided On : 21-05-2026

Advocates Appeared:
For the Petitioner:Ms. Vrinda Goyal, Mr. Vaibhav Maheshwari and Mr. Rahul Singh, Advocates.
For the Respondent:Mr. Kamal Kant Tyagi, Advocate

Judicial review of recruitment processes is limited to ensuring procedural legality and the absence of arbitrariness. Unless bias or mala fides is proven, courts will not substitute their assessment for that of selection committees, nor will they entertain challenges to completed selections without impleading the affected selected candidates.

Headnote:(A) Constitution of India - Articles 14 and 16 - Recruitment process - Public employment - Challenge to selection - Petitioner alleged inconsistency in marks communicated via official responses and questioned interview evaluation criteria - Court found that different numerical values reflected a mathematical conversion between scales rather than internal contradiction - No arbitrariness or mala fides established in the scoring methodology. (Paras 10-13, 19)

(B) Judicial Review - Scope and Ambit - Courts do not sit in appeal over recommendations of expert selection committees - Judicial intervention limited to examining the legality of process - Substitution of court's assessment for expert evaluation is impermissible absent proof of irrationality, mala fides, or violation of established policy. (Paras 8, 9, 16)

(C) Non-joinder of Necessary Parties - Writ petition challenging a selection process after results are declared and appointments made is unsustainable if the successful candidates, who are directly affected, are not impleaded in the proceedings. (Para 21)

Facts of the case:
The petitioner challenged the selection for an entry-level engineering position, claiming the process was arbitrary. The petitioner alleged that the disclosure of different scores for the written examination across two official communications indicated inconsistency. The respondent explained that raw marks were converted to a percentage-based scale as per policy, and that the petitioner failed to meet the qualifying threshold in the interview. Appointments were completed prior to the institution of the petition.

Findings of Court:
The court held that the mathematical conversion of marks across scales is not an inconsistency. Expert assessment in interviews involves permissible subjectivity, which does not amount to arbitrariness. Furthermore, the petition was deemed unsustainable due to the failure to implead the selected candidates whose rights would be affected.

Issues: The main issues were whether minor differences in numerical representations of marks create invalidating discrepancies, whether the court can supervise interview-based evaluations, and whether a petition can proceed without the presence of affected selected candidates.

Ratio Decidendi: Judicial review is restricted to the legality of a decision-making process. Administrative actions remain valid provided they are not influenced by oblique motives or manifest illegality. A selection process that has concluded cannot be set aside without providing affected parties an opportunity to be heard.

Result: Petition dismissed.

Table of Content
1. factual context regarding the challenge to a public sector recruitment process. (Para 1 , 2 , 3 , 4)
2. contrasting claims regarding procedural transparency and mathematical validity of examination scores. (Para 5 , 6)
3. limited scope of judicial review in matters concerning expert selection committees. (Para 7 , 8 , 9)
4. validity of score conversion methods in administrative recruitment. (Para 10 , 11 , 12 , 13)
5. requirement of holistic evaluation per prescribed criteria rather than reliance on written scores alone. (Para 14 , 15 , 16)
6. requirement of specific evidence for allegations of mala fides in subjective assessment processes. (Para 17 , 18)
7. dismissal of claims centered on unproven normalization of marks. (Para 19 , 20)
8. procedural necessity of impleading affected parties and the impact of laches on legal claims. (Para 21 , 22)
9. administrative lapses not amounting to illegality do not warrant interference with completed selections. (Para 23 , 24 , 25)

JUDGMENT :

SANJEEV NARULA, J.

1. The Petitioner, a student of Electronics and Communication Engineering at Delhi Technological University [“DTU”], has invoked the writ jurisdiction of this Court to challenge the selection process undertaken by Respondent No. 2, Bharat Electronics Limited [“BEL”], for recruitment to the post of Probationary Engineer through the campus recruitment process conducted during the year 2017-18.

2. The grievance in the present petition arises out of the Petitioner’s non-selection in the aforesaid recruitment process. The relief sought, inter alia, is in the nature of certiorari for quashing the selection list and a direction to the Respondents to conduct the selection process in a fair and transparent manner, in accordance with law.

Factual Background

3. BEL visited the campus of DTU for recruitment to the post of Probationary Engineer. The selection process comprised two stages, namely, a written test followed by an interview. The Petitioner participated in the selection process by appearing in the written test held on 2nd April, 2018 and the interview conducted on 3rd April, 2018. Upon completion of the selection process, the Petitioner was not included in the final list of selected candidates.

4. The Petitioner thereafter submitted representations dated 7th June, 2018 and 27th June, 2018 in relation to the recruitment process. He also sought information under the Right to Information Act, 2005 [“RTI Act”]. In response thereto, BEL, by communication dated 9th July, 2018, informed the Petitioner that he had secured “43.56 marks out of 85” in the written test and “04.00 out of 15.00 marks” in the interview. Subsequently, by communication dated 30th August, 2018, BEL informed the Petitioner that he had secured “30.75 out of 60 marks” in the written test and “4 out of 15 marks” in the interview.

Petitioner’s Contentions

5. In support of the petition, Ms. Vrinda Goyal, counsel for the Petitioner, makes the following submissions:

5.1. The selection process is vitiated by arbitrariness, lack of transparency and favouritism. The Petitioner had secured the highest marks in the written test, yet was excluded from the final list of selected candidates. Candidates who had secured lower marks in the written examination were selected by being awarded disproportionately high marks in the interview. Despite being the highest scorer in the written test, the Petitioner was effectively eliminated through the interview process.

5.2. The Respondents have not disclosed the basis, parameters or criteria on which marks were awarded in the interview. The Petitioner secured only 4 marks out of 15 in the interview and there is no material on record to demonstrate any objective assessment or evaluation. The methodology adopted for awarding interview marks, as well as the individual assessment forming the basis thereof, has not been disclosed. In the absence of any disclosed criteria governing the interview process, the interview marks were utilized to displa

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