1. A writ appeal challenges a single judge order concerning an expired recruitment process where appointments were already finalized. (Para 1 , 2 )
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2026 Supreme(Online)(MP) 123478
IN THE HIGH COURT OF MADHYA PRADESH AT GWALIOR
G. S. Ahluwalia, Pushpendra Yadav, JJ
Jitendra Singh Bhadoriya – Appellant
Versus
State of Madhya Pradesh – Respondent
WRIT APPEAL No. 1004 of 2026
Important Points
Courts generally refrain from unsettling a completed recruitment process and disturbing appointments already made, as it would be improper to upset the status of selected candidates who have already reported for duty.
Subject
Service Law - Recruitment
Act Referred
Headnote
(A) Recruitment Process - Completion of Selection - Unsettling appointments - Where the recruitment process has concluded and appointments have already been made, it is not proper to upset such appointments or unsettle the process at a belated stage. (Para 4)
Issues: Whether the court can unsettle a recruitment process after the appointments have already been made.
Issues: Whether the court can unsettle a recruitment process after the appointments have already been made.
Legal Category Hierarchy
Advocates:
For the Appellants/Petitioners: Prashant Sharma
For the Respondents: Kaushlendra Singh Tomar
For the Appellants/Petitioners: Prashant Sharma
For the Respondents: Kaushlendra Singh Tomar
Table of Contents
2. The dispute concerns whether an expired recruitment process, where selected candidates are already appointed and not impleaded, can be legally unsettled by the court. (Para 3 , 4 )
3. Following established precedent, the court observes that unsettled completed recruitment processes where appointees are not parties cannot be disturbed. (Para 4 , 5 , 6 )
4. Judicial interference in a completed recruitment process is impermissible where appointments have concluded and necessary parties were not impleaded in the legal proceedings. (Para 4 , 5 )
5. The writ appeal is dismissed as the court cannot grant relief in a completed recruitment process. (Para 6 , 7 )
6. Can a court unsettle a recruitment process once the selection is complete and candidates are appointed?
No, it is not proper for a court to upset such appointments, particularly when the selected candidates have not been impleaded as parties to the proceedings. (Para 4 , 5 )
7. Does a court have discretion to examine the merits of a challenge if the relief sought is procedurally unattainable?
No, the court considers it a futile attempt to deliberate on the merits of a case when no effective legal relief can be granted to the appellant due to the completion of the recruitment process. (Para 5 , 6 )
ORDER
Per: Justice Gurpal Singh Ahluwalia
1. This writ appeal under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyaypeeth Ko Appeal) Adhiniyam, 2005, is filed against the order dated 13/02/2026 passed by the learned Single Judge in Writ Petition No.3084/2010.
2. Undisputedly, the recruitment process in which the appellant wanted to participate has already come to an end and much water has flown under the bridge as the appointments have already been made.
3. The next question for consideration is as to whether this Court can unsettle the recruitment process at this stage or not.
4. The answer lies in the Judgment passed by Hon'ble Supreme Court in the case of Sushma Suri & Ors. Vs. Govt. of National Capital Territory of Delhi and Another reported in (1999) 1 SCC 330, in which it has been held as under:
"13. However, we are not in a position to give any relief to the appellant before us now because when she commenced this litigation, recruitment process was still going on and it has gone too far ahead. Now that the same is complete and the selected candidates have already been appointed and they have reported for duty at different places and they are not impleaded as parties in these proceedings, it would not be proper to upset such appointments. All that we can now do is to direct the authorities concerned including the High Court and Government to process the applications for recruitment of candidates in future in the light of the position as explained above. If there are any pending recruitments, the view taken by us shall be applied to them also. The appeal, therefore, stands disposed of in the manner stated above."
5. Since no relief can be granted to the appellant at this stage, it would be a futile attempt on the part of this Court to consider the merits of the case.
6. Accordingly, no case is made out warranting interference.
7. Consequently, this writ appeal fails and is hereby dismissed.
