B. AMRUTHA LAKSHMI versus STATE OF ANDHRA PRADESH AND ORS.

B. AMRUTHA LAKSHMI versus STATE OF ANDHRA PRADESH AND ORS.

The decision of the respondents not to consider eligible Assistant Commissioners for IAS selection, based on an unwritten seniority criterion, was violative of Arts. 14 and 16(1) of the Constitution, as it imposed an additional requirement not laid down in the regulations and resulted in discrimination among similarly situated officers.

Parties
Appellant: B. Amrutha Lakshmi; Respondents: State of Andhra Pradesh and Ors.
Jurisdiction
India
Judgment Date
18 October 2013
Procedural Posture
Civil Appeal / Supreme Court Judgment on Appeal From Andhra Pradesh High Court Decision and Central Administrative Tribunal Order
Outcome
Appeal partly allowed
Legal Topics
IAS Appointment by Selection, Public Employment, Equal Opportunity, Criteria for Selection, Damages for Unjust Non Consideration
Administrative Law Constitutional Law Employment Law IAS Appointment by Selection Public Employment Equal Opportunity Criteria for Selection Damages for Unjust Non Consideration

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Parties

B. Amrutha Lakshmi

Appellant

State of Andhra Pradesh and Ors.

Respondents

Procedural Posture

Civil Appeal / Supreme Court Judgment on Appeal From Andhra Pradesh High Court Decision and Central Administrative Tribunal Order

Legal Issues

  1. 1 Whether non-forwarding the names of eligible Assistant Commissioners of Commercial Taxes for selection to IAS under non-State Civil Services category violates applicable regulations and constitutional provisions
  2. 2 Whether imposition of seniority as an additional criterion is valid under IAS Appointment Regulations
  3. 3 Entitlement to be considered for appointment by selection based on outstanding merit and ability

Ratio Decidendi

The decision of the respondents not to consider eligible Assistant Commissioners for IAS selection, based on an unwritten seniority criterion, was violative of Arts. 14 and 16(1) of the Constitution, as it imposed an additional requirement not laid down in the regulations and resulted in discrimination among similarly situated officers.

Court Disposition

Appeal partly allowed

Orders

  • Impugned judgments of High Court and Central Administrative Tribunal set aside.
  • Court declares appellant and similarly situated persons entitled to be considered by committee if otherwise eligible; no further relief for past selection.