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2025 Supreme(Online)(SC) 10390

SUPREME COURT OF INDIA
Vijay Bishnoi, J
Leelavathi N. – Appellant
Versus
State of Karnataka – Respondent
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Advocates:
For the Appellants/Petitioners: D.L. Chidananda
For the Respondents: Tushar Mehta

Administrative tribunals are the exclusive courts of first instance for service-related disputes. High Courts should not entertain writ petitions challenging these matters if an effective statutory remedy exists, unless the case involves truly exceptional circumstances, such as fundamental rights violations or an absence of jurisdiction.

Headnote:(A) Administrative Tribunals Act, 1985 - Sections 15, 22, 24, 27 - Constitution of India - Article 226 - Service dispute - Recruitment process - Maintainability of writ petition before High Court - Administrative tribunals are designated as the courts of first instance for service matters - Whether High Court’s writ jurisdiction can be invoked in the presence of an efficacious alternative remedy - Court held that in matters of recruitment and service, litigants cannot bypass established statutory tribunals unless there exist exceptional circumstances such as violation of fundamental rights, failure of natural justice, or total lack of jurisdiction. (Paras 27, 36, 38, 46)

(B) Judicial Discipline - Rule of alternative remedy - High Court’s discretionary power to entertain writ petitions - Such power is not to be exercised as a matter of course when a comprehensive statutory mechanism for redressal exists. (Paras 31, 33, 37)

Facts of the case:
Candidates filed petitions challenging the rejection of their caste and income certificates during a government recruitment process for teaching positions. The primary contention involved whether parental or spousal certificates should be considered for the purpose of claiming reservation as a married female candidate. The High Court witnessed conflicting orders regarding the maintainability of these petitions, leading to an appeal before the Supreme Court.

Findings of Court:
The Court concluded that no exceptional circumstances existed to warrant the intervention of the High Court via its writ jurisdiction, as service disputes fall squarely within the domain of the Administrative Tribunal. The Tribunal possesses the necessary powers to regulate its procedure, pass interim orders, and punish for contempt, confirming its stature as an efficacious forum.

Issues: The main issues were whether the High Court is the maintainable forum for adjudicating service-related eligibility disputes during a recruitment process, and whether such disputes qualify as exceptional circumstances sufficient to bypass the statutory tribunal.

Ratio Decidendi: Tribunals constituted under the relevant service act act as the courts of first instance. The principle of exhaustion of statutory remedies must be strictly adhered to, as the High Court should only exercise writ jurisdiction in service matters where specifically prescribed exceptions, such as the challenge to the vires of a statute or fundamental rights violations, are present. Result : Appeals dismissed and matters relegated to the Administrative Tribunal.

Table of Content
1. initiation of appeal against high court judgment. (Para 1 , 2)
2. procedural history and factual background of the recruitment dispute. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13 , 14 , 15 , 16 , 20 , 21)
3. summary of rival arguments regarding selection lists and tribunal access. (Para 22 , 23 , 24)
4. tribunals hold exclusive jurisdiction for service matters per l. chandra kumar. (Para 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36 , 37)
5. administrative tribunals are empowered to provide complete adjudication and relief. (Para 38 , 39 , 40 , 41 , 42 , 43 , 44 , 45 , 46)
6. rejection of writ maintainability and lack of vested rights in provisional lists. (Para 47 , 48)
7. dismissal of appeals with directions for expedited tribunal resolution. (Para 49 , 50 , 51)

J U D G M E N T

VIJAY BISHNOI, J.

1. Leave granted.

2. These appeals have been preferred by the Appellants challenging the Judgment dated 12.10.2023 (hereinafter referred to as “impugned judgment”) passed in W.A. No.305/2023 (GM-CC); W.A. No.300/2023 (GM-CC); W.A. No.337/2023 (GM-CC); W.A. No.591/2023 (GM-CC); W.A. No.886/2023 (GM-CC) (hereinafter referred to as “the writ appeals”) by the High Court of Karnataka at Bengaluru (hereinafter referred as “the High Court”). The Division Bench of the High Court, thereby set aside the Judgment passed by the Single Judge Bench of the High Court in W.P. No. 23752 of 2022 (GM-CC) dated 30.01.2023, thus relegating the matter to the Karnataka State Administrative Tribunal (hereinafter referred to as “KSAT”) to be considered in a properly constituted application.

FACTUAL MATRIX

3. A notification dated 21.03.2022 was issued by the Department of Public Education, Government of Karnataka inviting applications for a total number of 15,000 posts of Graduate Primary Teachers for Classes 6-8 for 35 Educational Districts (hereinafter referred to as “recruitment notification”).

4. Pursuant to the said recruitment notification, examinations were held on 21.05.2022 and 22.05.2022. The Appellants and the private Respondents herein applied and participated in the said examinations. On 17.08.2022, the results of the said examinations were declared and accordingly, a provisional select list was published on 18.11.2022.

5. The provisional select list dated 18.11.2022 did not include the names of certain married individuals/candidates, who had applied in the OBC category, as they had not produced the caste cum income certificate (hereinafter referred to as “certificate”) of their husband but rather submitted the one issued in the name of their father. As a result of non-consideration of the certificate produced by them, the said individuals were found to be ineligible for reservation provided for the OBC category and hence, their names got reflected in the general merit list.

6. Aggrieved by the same, some of the private respondents herein approached the High Court by filing the Writ Petition No. 23752 of 2022 (GM-CC), praying to quash the provisional select list dated 18.12.2022 and seeking consideration of their names in the said provisional select list.

7. A similarly aggrieved candidate (private respondent herein) filed a Writ Petition bearing No. 200032 of 2023 before the High Court of Karnataka, Kalaburagi Bench, which came to be dismissed vide order dated 12.01.2023 as not maintainable. However, the Court granted liberty to the said writ petitioner to approach the Administrative Tribunal (hereinafter referred to as “Tribunal”) in view of the law laid down in L. Chandra Kumar vs. Union of India and Ors, reported in (1977) 3 SCC 261. Pursuant to the same, some similarly situated persons have approached the KSAT.

8. Despite the Order dated 12.01.2023 being passed by the Kalaburagi Bench of the High Court, the Single Judge of the High Court (Principal Bench) entertained the W.P. No. 23752 of 2025, presumably because the Order dated 12.01.2023 was not brought to its notice.

9. The Single Judge of the High Court

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2025 Supreme(Online)(SC) 10390

Cases Referred (2)