Meanwhile, the recruitment exam for the Physical Training Instructor post was held on September 25, 2022. Though the petitioner was initially selected, her appointment was later cancelled on the grounds that she did not possess the required qualification on the date of the recruitment examination.
The petitioner argued that the re-evaluation result should relate back to the original date of the qualifying exam, thereby rendering her eligible for the post as of September 25, 2022. In support of her claim, she cited several High Court decisions where courts had held that re-evaluation results declaring a candidate as "pass" would relate back to the original examination date.
High Court's Observation
However, the High Court firmly rejected this argument, placing reliance on the Supreme Court’s ruling in Jenany J.R. v. S. Rajeevan & Ors., where the Apex Court had ruled that revised marks awarded after re-evaluation would not retroactively replace the original result.
The Single Judge pointed out that in the judgments cited by the petitioner, the Jenany J.R. precedent was not brought to the attention of the coordinate benches, and therefore, those rulings could not be relied upon.
“Only view that holds the field is that the re-evaluation result would not relate back to the date of original declaration of result. Hence, one cannot claim himself/ herself as eligible for the advertised post, as he or she had been declared as ‘pass’ after the last date for submission of their application form,” the Court held.
Emphasizing the importance of stability in legal pronouncements, the Court stated that in a country governed by the Rule of Law, judgments, especially those of the Supreme Court, cannot be unsettled lightly.
“It is not permissible for the parties to re-open the concluded judgments as the same would not only tantamount to an abuse of the process of law and Court, but would also have a far-reaching adverse effect on the administration of justice,” the Court cautioned.
Concluding that there was no justification to depart from the binding precedent laid down by the Apex Court under Article 141 of the Constitution, the High Court dismissed the petition, thereby reinforcing the legal position that revised results cannot be treated as having retrospective effect in public recruitment matters.
Case Title: Kiran Yadav v. The State of Rajasthan & Ors.