Introduction

The case of Sukanta Pramanik and Ors. v. Syed Mohammad Ali and Ors. was adjudicated by the Calcutta High Court on January 11, 2024. This litigation arose from a contentious recruitment process for 2,000 "Bana Sahayaks" (Forest Assistants) employed on a contractual basis within five administrative divisions of West Bengal. The key issues centered on allegations of procedural irregularities, including the reduction of Engagement Board members and non-publication of the merit list, which led to unsuccessful candidates filing writ petitions challenging the selection process.

Summary of the Judgment

The High Court, presided over by Justices Tapabrata Chakraborty and V. M. Velumani, analyzed the merits of the writ petitions filed by five unsuccessful candidates. The Single Judge had previously directed a fresh recruitment process, citing procedural lapses. However, upon appeal, the Calcutta High Court set aside the Single Judge’s order, favoring the respondents and upholding the original selection process. The appellate bench ruled that the respondents lacked locus standi to challenge the selection post-participation and post-selection, and that the reduction of Engagement Board members from three to two did not inherently vitiate the selection process.

Analysis

Precedents Cited

The judgment extensively referenced prior cases to substantiate its reasoning:

• The State of West Bengal & Others v. Chandra Kanta Ganguli (2017 SCC OnLine Cal 3799): This case established that unsuccessful candidates in a fair selection process do not possess the locus standi to challenge the process post-selection.
• State of Uttar Pradesh v. Karunesh Kumar and Others (2022 SCC OnLine SC 1706): This Supreme Court judgment underscored that changes to the selection process after the commencement, especially post-application, cannot be justified unless they pertain to qualifications or eligibility criteria. It reinforced that procedural modifications not affecting candidate eligibility do not invalidate the selection process.

Legal Reasoning

The High Court meticulously dissected the arguments from both sides. The appellants contended that the Single Judge overstepped by directing a new selection process without compelling evidence of procedural malfeasance. They highlighted that:

• The reduction in board members was communicated before the conclusion of the selection process.
• No candidate was wrongly rejected based on this reduction.
• The merit list was made available publicly, albeit not via the website, which did not constitute a substantial lapse.

Conversely, the respondents argued that the deviation from the stipulated three-member Engagement Board to a two-member one compromised the fairness and transparency of the selection process. They alleged that this change could have influenced the merit outcomes adversely.

However, the High Court found these arguments unsubstantiated, noting that the modification did not alter the eligibility criteria and that the selection execution remained consistent across all candidates. The court emphasized that without concrete evidence of bias, discrimination, or procedural fraud, the selection process should stand firm.

Impact

This judgment reinforces the principle that administrative decisions in recruitment processes must adhere strictly to established procedures. It sets a precedent that mere procedural deviations, absent demonstrable adverse effects or malintent, do not warrant judicial intervention. Future recruitment drives will likely reference this case to delineate the boundaries of acceptable procedural modifications and to affirm the judiciary’s role in ensuring fairness without overstepping into administrative autonomy.

Complex Concepts Simplified

Conclusion

The Calcutta High Court's ruling in Sukanta Pramanik and Ors. v. Syed Mohammad Ali and Ors. underscores the judiciary's role in upholding procedural integrity in public sector recruitments. By dismissing the unwarranted challenges against the selection process, the court affirmed that administrative bodies retain the authority to conduct recruitment within the framework of established guidelines, provided there is no evidence of malfeasance or inherent unfairness. This judgment serves as a crucial reference point for both applicants and administrative entities, delineating the scope of legal interventions in recruitment disputes.