R. RANJITH SINGH & ORS. versus THE STATE OF TAMIL NADU & ORS.

R. RANJITH SINGH & ORS. versus THE STATE OF TAMIL NADU & ORS.

The amendment to Rule 25(a) contained in G.O. dated 21.11.2017 insofar as it grants en bloc seniority to departmental (in-service) direct recruits over open-market direct recruits and its retrospective application from 13.07.1995 is violative of Articles 14, 16 and 21 and is struck down; reservation of 20% of direct recruitment vacancies for in-service candidates is permissible, but inter-se seniority for all direct recruits must be determined solely on the basis of ranks/marks assigned by the appointing authority and all gradation lists from 1995 are to be recast on that basis.

Parties
Appellants: R. Ranjith Singh & Ors.; Respondents: The State of Tamil Nadu & Ors.
Jurisdiction
India
Judgment Date
01 May 2025
Procedural Posture
Civil Appeal / Appeal Against Judgment of the High Court of Judicature at Madras (wp No. 25263/2009 and WP No. 33544/2018) Before the Supreme Court
Outcome
Appeals disposed of; G.O. dated 21.11.2017 quashed insofar as it amends Rule 25(a) to grant en bloc seniority to departmental direct recruits and such amendment struck down as violative of Articles 14, 16 and 21; reservation of 20% departmental quota under direct recruitment upheld.
Legal Topics
Fixation of Inter Se Seniority, Direct Recruitment, In Service Reservation Quota, Retrospective Amendment, Executive Instructions Vs Statutory Rules, Seniority Based on Merit/marks
Constitutional Law Administrative Law Service Law Fixation of Inter Se Seniority Direct Recruitment In Service Reservation Quota Retrospective Amendment Executive Instructions Vs Statutory Rules +1 more

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Parties

R. Ranjith Singh & Ors.

Appellants

The State of Tamil Nadu & Ors.

Respondents

Procedural Posture

Civil Appeal / Appeal Against Judgment of the High Court of Judicature at Madras (wp No. 25263/2009 and WP No. 33544/2018) Before the Supreme Court

Legal Issues

  1. 1 Whether amendment to Rule 25(a) by G.O. dated 21.11.2017 granting en bloc seniority to departmental (in-service) direct recruits over open-market direct recruits is valid
  2. 2 Whether retrospective application of the amendment from 13.07.1995 is constitutionally permissible (Articles 14, 16 and 21)
  3. 3 Whether executive instructions issued prior to statutory amendment could supplant the statutory recruitment rules

Ratio Decidendi

The amendment to Rule 25(a) contained in G.O. dated 21.11.2017 insofar as it grants en bloc seniority to departmental (in-service) direct recruits over open-market direct recruits and its retrospective application from 13.07.1995 is violative of Articles 14, 16 and 21 and is struck down; reservation of 20% of direct recruitment vacancies for in-service candidates is permissible, but inter-se seniority for all direct recruits must be determined solely on the basis of ranks/marks assigned by the appointing authority and all gradation lists from 1995 are to be recast on that basis.

Court Disposition

Appeals disposed of; G.O. dated 21.11.2017 quashed insofar as it amends Rule 25(a) to grant en bloc seniority to departmental direct recruits and such amendment struck down as violative of Articles 14, 16 and 21; reservation of 20% departmental quota under direct recruitment upheld.

Orders

  • Respondents shall recast all gradation lists in respect of direct recruitment (including 20% in-service direct recruits) by granting seniority solely on the basis of marks obtained in the qualifying examination/selection process; recasting and issuance of revised gradation lists to be completed within 60 days
  • Respondent State shall not revert any officer who has received further promotion based on earlier seniority lists from 1995; however, no new promotion orders shall be issued in respect of departmental candidates until the revised seniority list is issued