State rules in public recruitment that discriminate against citizens based on their specific place of residence or source of nomination within the state are arbitrary and violate constitutional guarantees of equality, unless such requirements are established by valid Parliamentary law.

These set of writ petitions have been taken up together and are being disposed off by this common judgment.

2. We have heard Mr. B.J. Mukherjee, learned Advocate for the petitioners in WP(C) No.143/2026; Mr. S. Borgohain, learned Advocate for the petitioners in WP(C) No.693/2025; Mr. B.D. Das, learned Senior Advocate assisted by Mr. J. Lotha, learned Advocate for the petitioners in WP(C) No.1865/2026; Mr. A.K. Baruah, learned Advocate for the petitioners in WP(C) No.2071/2026; Mr. T. Deuri, learned Advocate for the petitioners in WP(C) No.2026/2026; Ms. B. Bhuyan, learned Senior Advocate, assisted by Ms. R. Das, learned Advocate for BTC; Mr. R. Borpujari, learned Standing Counsel, Revenue and Disaster Management Department; Mr. D. Thaosen, learned Standing Counsel, N.C. Hills Autonomous Council.

3. The petitioners, all of whom have undergone the Recorders’ Certificate Class Course (hereinafter to be referred as “RCCC”) training from the Assam Survey and Settlement Training Centre of the Government of Assam, under Revenue and Disaster Management Department in various sessions from 2017 to 2024, have questioned the validity of Rule 5 (1A) of the Assam Land Records Subordinate Service (Amendment) Rules, 2025, which amends the Assam Land Records Subordinate Service Rules, 2023 (hereinafter to be referred as the “Rules of 2023”), thereby allowing only pre-trained RCCC candidates to appear for recruitment to the entry level post of Land Records Assistant (equivalent to Lot Mandal), as a one-time measure, but explicitly excluding the candidates nominated by Territorial and Autonomous Council areas, like, Bodoland Territorial Autonomous Council, N.C. Hills Autonomous Council, etc., on the ground of the same being arbitrary,

4. violative of the fundamental rights of the petitioners and that the amendment, in effect, causes discrimination based on residence or places of birth, despite some of them being non-tribals and not claiming any tribal priority rights.

The Recorders’ Certificate Class Course (RCCC) is a 6(six) months’ training course imparted by the Assam Survey and Settlement Training Centre, which, this Court has been informed, is presently the only Training Institute in the State of Assam for providing training to the aspirants for the posts of Revenue officials and Recorders. This Training Course has been designed with an objective to train the candidates with the duties of Recorders and passing of this Course was considered to be a necessary/pre-requisite for appointment to the posts of Lot Mandals in different districts of Assam.

The petitioners were nominated for training by the respective Autonomous Councils, depending upon their places of residence.

5. It would be relevant here in this context to state that the Government of Assam framed the Rules of 2023, which stood notified on 27.03.2023 and came in to force with effect from 01.04.2023.

6. Prior to the enactment of the Rules of 2023, referred to above, Lot Mandals were appointed by the Directorate of Land Records and Surveys, Assam, as per district-wise vacancies and for all such recruitments, the candidates were required to have a pass certificate of the Recorders’ Certificate Class Course (RCCC) training.

The Rules of