Harmonious Operation of Rank‑List Validity and Communal Rotation under the Cochin University of Science and Technology Act: A Commentary on Radhika T. v. Cochin University of Science and Technology, 2025 INSC 1462

1. Introduction

The Supreme Court of India’s decision in Radhika T. v. Cochin University of Science and Technology & Ors., 2025 INSC 1462, clarifies a critical intersection between two competing statutory commands in university service law:

• the validity and use of a rank list/wait list for appointments; and
• the mandatory application of communal rotation/reservation.

The Court authoritatively holds that under the Cochin University of Science and Technology Act, 1986 (“CUSAT Act”), the provision that a rank list remains valid for two years and must be used to fill all vacancies arising in that period cannot be read as suspending or postponing the operation of communal rotation. Both provisions must function simultaneously.

The judgment also establishes that once a vacancy reserved for a particular community (here, Scheduled Castes) has been substantively filled by appointment and probation declaration, the reservation for that roster point is “satisfied in form and substance”. A subsequent vacancy arising from resignation of that appointee is treated as a fresh vacancy to be filled strictly according to the next point in the communal roster – not as a continuing reserved vacancy to which the next candidate in the rank list from the same community can lay claim.

This commentary examines the factual context, the legal issues, the Court’s reasoning, and the wider doctrinal and practical implications of this ruling.

2. Factual Background and Procedural History

2.1 The parties and the post

• Appellant: Radhika T., a candidate belonging to the Scheduled Caste (SC) community.
• Respondent: Cochin University of Science and Technology (CUSAT) and its Registrar.
• Post involved: Associate Professor, Inorganic Chemistry, in the Department of Applied Chemistry.
• Nature of post: A single post, specifically reserved for Scheduled Caste as per the recruitment notification dated 22.10.2019.

2.2 History of the vacancy

• The same post had been notified earlier in 2005 and 2015 as SC-reserved, but remained unfilled for want of suitable SC candidates.
• In 2019, it was again notified as an SC-reserved vacancy.

2.3 The 2019 recruitment and the rank list

• Radhika applied pursuant to the 22.10.2019 notification.
• A selection process was held; a rank list (wait list) was published on 15.02.2021.
• The rank list was expressly stated to be valid for two years from publication (15.02.2021 to 14.02.2023), in line with Section 31(10) CUSAT Act.
• Rank 1: Dr. Anitha C. Kumar (SC)
• Rank 2: Radhika T. (SC – appellant)
• Dr. Anitha was appointed to the post; she joined and her probation was declared.

2.4 Resignation of the appointee and the new vacancy

• On 30.03.2022, within the two-year validity of the rank list, Dr. Anitha resigned after securing a substantive appointment as Professor in Mahatma Gandhi University.
• This created a vacancy in the same post during the currency of the rank list.

2.5 University’s shifting stands and earlier litigation

1. First rejection (20.04.2022): “Lien” ground
   When Radhika requested appointment as the next candidate in the rank list, the University rejected her request asserting that Dr. Anitha retained a lien on the post, hence it could not be offered to Radhika.
   Radhika challenged this via W.P.(C) No. 15183 of 2022.
   The High Court allowed her petition, rejecting the lien argument and directing the University to reconsider her claim subject to communal rotation.
2. Second rejection (16.09.2022): “Fresh vacancy under communal rotation” ground
   Upon reconsideration, the University took a different stance:
   • It treated the vacancy as a fresh vacancy arising after the SC reservation for that post had already been satisfied by Anitha’s appointment; and
   • Invoked Section 31(11) (communal rotation) to hold that the vacancy now belonged to the Latin Catholic/Anglo Indian (LC/AI) category.
   Radhika’s claim was again rejected.

2.6 High Court proceedings leading to the Supreme Court

• Radhika filed W.P.(C) No. 38986 of 2022 challenging the 16.09.2022 rejection.
• The learned Single Judge dismissed the writ petition (03.02.2023), upholding the University’s position.
• Writ Appeal No. 534 of 2023 was also dismissed by a Division Bench (12.07.2023).
• Review Petition No. 1202 of 2023 was dismissed as well (13.09.2025).
• Radhika then approached the Supreme Court by way of special leave; leave was granted, and these appeals were heard and decided by a Bench of Aravind Kumar, J. and N.V. Anjaria, J. (Judgment authored by N.V. Anjaria, J.).

3. Core Legal Issues

The central issues before the Supreme Court were:

1. Interplay of Section 31(10) and Section 31(11) of the CUSAT Act
   When a rank list is valid for two years and “all vacancies arising during the period shall be filled up from the list” (Section 31(10)):
   • Can the next candidate in the rank list claim appointment as of right when a vacancy arises during this period?
   • Or must the vacancy still be filled according to the communal rotation (Section 31(11)), even if that means bypassing the next candidate in the list?
2. Nature of the vacancy after the SC appointee resigned
   Did the resignation of an SC appointee from an SC-reserved post:
   • revive an SC-reserved vacancy (enabling appointment of the next SC candidate in the rank list, i.e., Radhika), or
   • create a fresh vacancy to be allotted as per the next point in the communal roster (here, LC/AI)?
3. Extent of right of a wait‑listed candidate
   Does inclusion in a valid rank list confer on a candidate an enforceable right to appointment whenever a vacancy arises during the validity period?
4. Validity of “lien” as a ground to deny appointment
   Could the University lawfully rely on the concept of lien to deny appointment to the appellant after the original appointee had resigned and taken up another substantive post elsewhere?

4. Summary of the Supreme Court’s Judgment

The Supreme Court dismissed the appeals and affirmed the High Court’s decision. Its key holdings can be summarised as follows:

1. No priority of rank list over communal rotation
   Section 31(10) (two-year validity of rank list and filling all vacancies from it) and Section 31(11) (communal rotation) must be read harmoniously. They are not mutually exclusive. Every appointment made during the validity of a rank list must also adhere to communal rotation.
2. Reservation for SC vacancy was already “satisfied”
   Once the reserved SC post was actually filled and probation declared by an SC candidate (Dr. Anitha), the SC reservation for that roster point was satisfied in form and substance. Her subsequent resignation created a new vacancy which, under the rotation, fell to the Latin Catholic/Anglo Indian category.
3. No vested right from inclusion in the rank list
   Radhika’s position as Rank 2 in a still‑valid rank list did not confer a vested or indefeasible right to appointment. Her claim was conditional on:
   • a vacancy arising within the list’s validity; and
   • her category matching the category to which the vacancy belonged under the communal roster.
   As the vacancy was now an LC/AI turn, she could not claim appointment.
4. “Lien” argument rejected as legally untenable
   Invoking the concept of lien to deny Radhika’s claim was held to be erroneous in law. Once an employee is appointed substantively to another post, the lien on the previous post automatically ends. Hence, Dr. Anitha had no lien on the CUSAT post after joining Mahatma Gandhi University.
5. University correctly applied communal rotation
   It was lawful for CUSAT to assign the fresh vacancy to Roster Point 8 – LC/AI and to refuse appointment to Radhika, as she did not belong to that category and there was no eligible LC/AI candidate in the rank list.

5. Detailed Legal Analysis

5.1 Statutory framework

5.1.1 CUSAT Act, 1986 – Section 31

The key provisions are:

• Section 31(9): Rank lists prepared by Selection Committees must be published on the notice board and in the Gazette.
• Section 31(10):
  “A rank list published under sub section (9) shall remain in force for a period of two years from the date of such publication and all vacancies arising during the period shall be filled up from the list so published.”
• Section 31(11):
  “Communal rotation shall be followed category-wise treating all the departments as one unit.”
• Section 31(12): The Registrar shall maintain a register showing:
  • appointments made;
  • vacancies filled by open competition and by reserved categories (SC/ST/OBC);
  • vacancies unfilled for want of qualified reserved-category candidates and carried forward, etc.

5.1.2 Section 7(2) CUSAT Act and the Kerala State & Subordinate Service Rules, 1958 (KSSR)

Section 7(2) mandates that, in making appointments, CUSAT must mutatis mutandis follow Rule 14 and Rules 15, 16, 17, 17A of the KSSR.

• Rule 14 KSSR – Reservation of appointments:
  • Sub-rule (a): Provides for appointments from reserved categories.
  • Sub-rule (b): Allows SC/ST candidates to compete in open merit as well.
  • Sub-rule (c): Specifies the order of rotation for every cycle of 20 vacancies.
• Rule 15 KSSR – Combining rotation into an integrated cycle:
  • Crucially, its Explanation defines “selection year”:
    “The ‘selection year’ for the purpose of this rule shall be the period from the date on which the Rank List of candidates comes into force up to the date on which it expires.”

This structure reveals the legislative design: the period of a rank list’s validity (the “selection year”) is the window within which communal rotation is expected to operate. The rank list supplies the pool; the rotation decides who gets which vacancy from that pool.

5.2 Harmonious construction of Section 31(10) and 31(11)

Radhika’s core argument was that Section 31(10), by mandating that “all vacancies arising during” the two-year period “shall be filled up from the list”, effectively postpones the application of Section 31(11) until after the rank list expires. In her reading, communal rotation should “wait” until the two years end, ensuring that the rank list is fully exhausted on merit within the initially advertised category.

The Court rejected this interpretation as inconsistent with the doctrine of harmonious construction, drawing on CIT v. Hindustan Bulk Carriers (2003) 3 SCC 57 and State of Gujarat v. R.A. Mehta (2013) 3 SCC 1.

5.2.1 Principles of harmonious construction

• Different provisions of a statute should be construed to make them effective and operative, not redundant.
• A construction that reduces one provision to a “useless lumber” or “dead letter” must be avoided.
• The maxim ut res magis valeat quam pereat applies – laws should be interpreted so that they have effect, not so they become void or inoperative.

Applied to the CUSAT Act, this means:

• Section 31(10) and Section 31(11) are intended to work together, not sequentially.
• Allowing Section 31(10) to suspend Section 31(11) for a full two-year period would render the communal rotation requirement functionally inoperative for that period, which is unacceptable under the harmonious construction doctrine.

5.2.2 Court’s resolution of the “conflict”

The Court held that:

• Section 31(10) merely defines the life span of the rank list and directs that vacancies during that span must be filled from that list (as a source of candidates).
• Section 31(11) determines the allocation of each vacancy to specific communities via communal rotation.
• The correct reading is that:
  “the Rank List continues to be valid for a period of two years as per section 31(10), and within this period, every appointment made therefrom must adhere to the communal rotation mandated by section 31(11) of the University Act…”

Thus, the rank list’s validity does not override or defer communal rotation; rather, every appointment drawn from the list must conform to the roster.

5.3 Nature and operation of rank lists/wait lists

5.3.1 The general legal position – Gujarat Dy. Engineers and others

The Court surveyed several precedents on the nature of wait lists/rank lists:

• Gujarat State Dy. Executive Engineers’ Assn. v. State of Gujarat, 1994 Supp (2) SCC 591
• Surender Singh v. State of Punjab, (1997) 8 SCC 488
• Rakhi Ray v. High Court Of Delhi, (2010) 2 SCC 637
• Vivek Kaisth v. State of Himachal Pradesh, (2024) 2 SCC 269
• Raj Rishi Mehra v. State Of Punjab, (2013) 12 SCC 243

The consolidated principle, particularly drawing from Gujarat State Dy. Executive Engineers’ Assn., is:

The Court in Radhika T. accepts this general rule, but emphasises two refinements:

1. Statutory validity matters – When the law itself (as here, Section 31(10)) prescribes a validity period and mandates that vacancies “shall be filled” from the list, the list cannot be treated as purely discretionary. However, that mandate is still subject to other binding provisions, such as communal rotation.
2. Right is conditional, not absolute – Even within the validity period, the right of a wait‑listed candidate is contingent upon:
   • a vacancy actually falling to the candidate’s category under the roster; and
   • no contrary statutory rule governing how that vacancy must be filled.

5.3.2 Distinguishing “number of vacancies” line of cases

Cases like Surender Singh and Rakhi Ray primarily deal with:

• the impermissibility of filling vacancies in excess of those advertised, and
• the principle that a wait list cannot be used as a reservoir to fill vacancies arising long after the recruitment process, when new eligible candidates might have emerged.

In Radhika T., the problem is of a different type:

• the vacancy does arise within the advertised period and within the validity of the rank list;
• the question is not whether it can be filled from the existing list, but which category the vacancy belongs to according to the communal roster.

Thus, these earlier cases inform the absence of any absolute right to appointment from the rank list, but do not directly answer the communal rotation issue; that is resolved by the CUSAT-specific statutory scheme and harmonious construction.

5.4 Reservation, communal rotation and when a reserved vacancy is “satisfied”

5.4.1 The Narayanan decision of the Kerala High Court

Radhika relied heavily on Narayanan v. State Of Kerala, 1981 SCC OnLine Ker 14, a Division Bench decision of the Kerala High Court involving:

• recruitment of Section Officers in the Legislature Secretariat under Rule 17A KSSR (special recruitment for SC/ST);
• a rank list where:
  • Candidate at Rank 1 (K.M. Mary, an SC candidate) was advised for an ST-reserved post but did not join;
  • Petitioner (Narayanan), an ST candidate at Rank 2, sought appointment to that ST post.

The Public Service Commission treated the vacancy as fresh and open to all SC candidates, ignoring the ST candidate next in line. The High Court held:

The Court in Narayanan thus insisted that:

• the class for which the reservation is meant (there, Scheduled Tribe) should get an actual appointment to the reserved slot, not just an advice; and
• if the first advised candidate does not join, the next candidate from the same class in the rank list should be appointed.

5.4.2 Why Narayanan does not help the appellant

The Supreme Court carefully distinguishes Narayanan on multiple grounds:

1. Non-joining vs. resignation after appointment
   In Narayanan, the first candidate never joined, meaning:
   • no actual appointment of the reserved class occurred; and
   • the reserved vacancy remained unfilled.
   Therefore, allowing the next eligible candidate from the same reserved class to be appointed was necessary to give reservation “in substance”.
2. In Radhika’s case, the SC reservation was fully worked out
   Dr. Anitha:
   • was appointed to the SC-reserved post;
   • joined duty; and
   • had her probation declared.
   At that point, the SC reservation for that roster slot was complete. Her later resignation does not retroactively undo the “satisfaction” of the SC reservation for that vacancy.
3. Crucial caveat within Narayanan itself
   The Supreme Court highlights a key sentence in Narayanan:
   “When once a person advised is appointed whether subsequently he continues or not in that post is another matter.” (emphasis supplied)
   This supports the distinction:
   • Reservation must ensure an actual appointment for that class; but
   • Once appointment occurs, subsequent non-continuance (resignation, etc.) does not make the reservation incomplete.

Thus, in Radhika T., the SC reservation had already been honoured in substance. The vacancy that arose on resignation was a new vacancy to be placed in the next roster slot (LC/AI), not a continuing SC vacancy.

5.5 The concept of “lien” and its misuse

5.5.1 What is lien in service law?

Lien is a service law concept denoting a government servant’s right to hold a post substantively. The Court relied on:

• Ramlal Khurana v. State of Punjab, (1989) 4 SCC 99
• State of Rajasthan v. S.N. Tiwari, (2009) 4 SCC 700

In Ramlal Khurana, the Supreme Court explained:

This was reaffirmed in S.N. Tiwari, where the Court held that lien on an earlier post automatically terminates upon substantive appointment to another post.

5.5.2 Application in the present case

CUSAT initially argued that Radhika could not be appointed because Dr. Anitha retained a lien on the Associate Professor post, despite:

• her formal resignation; and
• her substantive appointment to a new post in Mahatma Gandhi University.

The Supreme Court held this to be “entirely erroneous in law”:

• On resignation and appointment to another substantive post, any lien on the CUSAT post stood terminated automatically.
• No separate order was necessary to extinguish that lien.
• As such, the lien ground could not be used to deny Radhika consideration.

Although this lien ground had already been rejected earlier by the High Court in W.P.(C) No. 15183 of 2022, CUSAT inexplicably reiterated it in its counter-affidavit before the Supreme Court. The Court’s clarification here reinforces an important service law principle for all public employers.

5.6 Application of the law to the facts

The Court’s reasoning, step by step, proceeds as follows:

1. Was the SC reservation for this post satisfied?
   Yes. The SC-reserved post was:
   • filled by appointing an SC candidate (Dr. Anitha);
   • her probation was declared; and
   • she functioned in the post for more than one year.
   Therefore, the SC reservation for that roster point was satisfied in substance.
2. What happened upon resignation?
   When Dr. Anitha resigned on 30.03.2022, a vacancy arose in the cadre of Associate Professor (Inorganic Chemistry). This vacancy:
   • arose during the currency of the rank list (15.02.2021–14.02.2023);
   • therefore, under Section 31(10), it had to be filled, if possible, from the same rank list.
3. Which communal category did this vacancy belong to?
   Under the communal rotation (Section 31(11) read with KSSR), after the SC point had been utilised for this post, the next vacancy was due for the Latin Catholic/Anglo Indian (LC/AI) category (identified as “turn 8 – LC/AI” in the roster).
4. Could Radhika, as an SC candidate at Rank 2, claim this vacancy?
   No. Even though:
   • the vacancy arose within the list’s validity; and
   • Radhika was next in the rank list,
   she belonged to the SC category, not LC/AI. Section 31(11) demanded that this particular vacancy be filled from LC/AI. Therefore, the rank list could be used only if it contained an LC/AI candidate at an appropriate rank. Since no candidate (including Radhika) in the rank list met this communal requirement, she had no right to claim this vacancy.
5. Were the University’s actions lawful?
   Yes. The University:
   • correctly identified that the fresh vacancy fell to LC/AI as per the rotation; and
   • was justified in not offering the post to Radhika.
   The Court thus upheld CUSAT’s decision to treat the vacancy as an LC/AI turn and to proceed accordingly.

6. Precedents Cited and Their Influence

6.1 CIT v. Hindustan Bulk Carriers, (2003) 3 SCC 57

This case was cited for the doctrine of harmonious construction. The Supreme Court in that case held that:

• Statutory provisions must be construed so that each has effect.
• One provision should not be interpreted to render another provision a “dead letter”.

In Radhika T., this principle is applied to avoid reading Section 31(10) in a manner that would nullify Section 31(11) for the entire two-year period of the rank list’s validity.

6.2 State of Gujarat v. R.A. Mehta, (2013) 3 SCC 1

R.A. Mehta also emphasised the maxim ut res magis valeat quam pereat and the need to interpret statutes to make them workable. The Court in Radhika T. follows this line, ensuring that both rank-list validity and communal rotation operate concurrently and effectively.

6.3 Ramlal Khurana and S.N. Tiwari – Lien

These cases define the nature of lien in service law and affirm that lien on a previous post ends automatically when an employee is substantively appointed to a new post. They are used here to demolish the University’s first (and legally flawed) attempt to deny Radhika’s claim.

6.4 Narayanan v. State Of Kerala, 1981 SCC OnLine Ker 14

While Narayanan is invoked by Radhika to stress that reservation must be meaningful in substance and not merely at the stage of advice, the Supreme Court in Radhika T.:

• accepts its core principle (reservation must lead to real appointments for the reserved class); but
• distinguishes it factually (non-joining vs. resignation after appointment); and
• relies on Narayanan’s own caveat that once a person is appointed, whether they continue or not is “another matter”.

Thus, Narayanan ultimately supports the view that the SC reservation for this post had been fully worked out once Dr. Anitha was appointed and completed probation.

6.5 Surender Singh and Rakhi Ray – Excess appointments and wait lists

Both cases reiterate that:

• Appointments cannot be made in excess of the number of advertised vacancies.
• A wait list cannot be used as a perpetual reservoir to fill post‑advertisement vacancies.

In Radhika T., these cases are used to:

• underscore that inclusion in a wait list does not create a general right to appointment; and
• highlight that any right from a wait list is necessarily limited and subject to the governing rules.

6.6 Vivek Kaisth and Raj Rishi Mehra – No vested right from wait list

These decisions reinforce that:

• wait-listed candidates have no vested right to demand appointment;
• in the absence of a statutory duty to fill vacancies from a wait list, authorities are not bound to appoint wait-listed candidates.

In Radhika T., the Court accepts this general doctrine, but notes that Section 31(10) of the CUSAT Act does impose a statutory direction to fill vacancies from the rank list during its validity – yet still subject to communal rotation.

6.7 Gujarat State Dy. Executive Engineers’ Assn. v. State of Gujarat, 1994 Supp (2) SCC 591

This case is central for understanding the role of wait lists. The Supreme Court explained that:

• A wait list is linked to the selection for a defined set of vacancies (plus those reasonably foreseeable, e.g., retirements within a year).
• Its “mainly intended” function is to ensure that if selected candidates do not join, substitutes are readily available.
• It is “not a reservoir for filling up future vacancies” beyond those contemplated.

In Radhika T., these principles are acknowledged, but the existence of an express statutory provision (Section 31(10)) providing a two-year validity and mandating filling “all vacancies” from the list slightly alters the normal discretionary character of a wait list. Even so, the Court holds that this statutory mandate does not override the equally mandatory communal rotation requirement.

7. Simplifying Key Legal Concepts

7.1 Rank list vs. wait list

• A rank list is an ordered list of candidates who have been found suitable in a selection process, arranged in order of merit.
• The term wait list is often used interchangeably, especially for candidates listed below the number of notified vacancies.
• Inclusion in such a list does not give an automatic right to appointment; it only creates a possibility of appointment if:
  • a vacancy arises within the validity period; and
  • the governing rules permit or direct filling that vacancy from the list.

7.2 Communal rotation and reservation

• Reservation ensures a proportion of posts are earmarked for particular social groups (e.g., SC, ST, OBC, certain communities).
• A communal rotation or roster is a pre‑arranged sequence (cycle) which assigns each successive vacancy to a particular category (Open, SC, ST, OBC, specific communities etc.).
• Every new vacancy is matched to a roster point, determining which category it belongs to, regardless of the post’s earlier occupant.

7.3 “Selection year”

• Under KSSR Rule 15, “selection year” is defined as the period from the date a rank list comes into force until its expiry.
• This period is relevant both for:
  • filling vacancies from that rank list; and
  • ensuring that the communal rotation operates across all appointments in that period.

7.4 Lien

• Lien is the right of a government servant to hold a particular post substantively.
• When a person is substantively appointed to a new post:
  • they acquire lien on the new post; and
  • their lien on the old post automatically ceases.
• No special order is necessarily required to extinguish the old lien.

8. Impact and Implications

8.1 For universities and public institutions using rank lists

• Institutions governed by statutes similar to the CUSAT Act must recognise that:
  • a statutory rank list’s validity and mandatory usage clause do not suspend communal rotation; and
  • every appointment from the list must still adhere to the applicable reservation roster.
• Recruitment authorities must ensure that:
  • when a vacancy arises within the list’s validity, they identify the correct roster point first; and
  • only then look to the rank list for a candidate of the appropriate category.

8.2 For reserved category candidates

• The decision draws a clear line between:
  • a reserved vacancy which is yet to be filled (where the reserved class has a strong claim to ensure actual appointment), and
  • a vacancy that arises after a substantive appointment has been made and probation declared for that reserved slot.
• Once an SC/ST/OBC candidate has been appointed and has served in the post, the community’s right to that particular roster point is treated as fulfilled, even if the appointee later resigns. Future claims must then be evaluated by reference to the next roster points.

8.3 For the doctrine of wait lists

• The judgment reaffirms that wait lists are not independent sources of recruitment. Their operation is circumscribed by:
  • the number and nature of vacancies initially contemplated;
  • the statutory validity period; and
  • other binding rules like communal rotation.
• Even when a statute directs that all vacancies during a period “shall be filled” from a list, such a direction is not absolute – it is mediated by other statutory provisions, especially reservation rules.

8.4 For statutory interpretation

• The judgment provides a clear contemporary application of harmonious construction:
  • Two apparently conflicting sub-sections are reconciled by giving each a distinct, co‑existing role.
  • Court refuses to “suspend” one provision in favour of another for an entire period (here, two years).
• This approach is likely to influence future cases where validity clauses for select lists interact with reservation provisions under various state and university statutes.

9. Conclusion

Radhika T. v. Cochin University of Science and Technology is a significant decision in the field of public employment, reservation, and university service law. The Supreme Court clarifies that:

• A statutory rank list’s validity and compulsory usage clause (Section 31(10) CUSAT Act) cannot be read to eclipse the communal rotation mandate (Section 31(11)).
• Both must operate simultaneously – every appointment from a valid rank list must fit into the communal roster.
• Reservation for a particular roster point is considered exhausted once a candidate from the reserved class is substantively appointed and serves in the post; later resignation does not revive that roster point for the same community.
• Wait-list candidates do not enjoy an indefeasible right to appointment; their prospects are always subject to the structure of vacancies under the communal roster and other statutory mandates.
• The concept of lien cannot be improperly invoked once an employee resigns and holds a substantive appointment elsewhere.

In dismissing Radhika’s appeals, the Court upholds the integrity of the communal rotation system while respecting the statutory framework governing rank lists. The decision provides clear guidance on how future vacancies arising within the currency of rank lists must be handled, ensuring that both merit and reservation operate in a coherent, legally consistent manner.