3.1 Precedents Cited

The judgment extensively references landmark cases that shape the doctrine of legitimate expectation both under common law and Indian jurisprudence:

• Schmidt v. Secretary of State for Home Affairs: Introduced the modern conception of legitimate expectation, emphasizing procedural fairness.
• O'Reilly v. Mackman: Reinforced the authority of courts to review administrative actions that breach legitimate expectations.
• Food Corporation of India v. Kamdhenu Cattle Feed Industries: Integrated the doctrine into Indian law, linking it to Article 14's mandate against arbitrariness.
• Hindustan Development Corporation v. Union of India: Clarified that legitimate expectation must be based on law, custom, or established procedure.
• Punjab Communication Ltd v. Union of India: Distinguished between procedural and Substantive Legitimate Expectations.
• State of Jharkhand v. Brahmputra Metallics and Shyama Nandan Mishra: Addressed the balance between legitimate expectations and overriding public interest.

These precedents collectively underscore the necessity for public authorities to adhere to established procedures and honor prior commitments unless compelling public interests necessitate deviation.

3.2 Legal Reasoning

The Court's legal reasoning is anchored in the following key principles:

• Ultra Vires Action: The High Court's imposition of a viva-voce cut-off was beyond its legal authority as per the 1961 Rules, which explicitly disallowed such a provision.
• Doctrine of Legitimate Expectation: The petitioners had a justified expectation based on the clear clauses in the Rules, the examination scheme, and the 2015 notification that the merit list would be based solely on aggregate marks without a viva-voce cut-off.
• Principles of Good Administration: Emphasized the need for consistency, transparency, and predictability in administrative actions to prevent arbitrariness.
• Violation of Article 14: By arbitrarily altering the selection criteria without proper legal basis or notice, the High Court violated the principle of equality before the law.

The Court balanced the High Court's rationale for ensuring "practical wisdom" and "personality" against the statutory framework and concluded that procedural deviations without proper amendments were unlawful.

3.3 Impact

This judgment has significant implications for administrative procedure and judicial appointments:

• Reinforcement of Rule of Law: Affirmed that public authorities must operate within the bounds of established rules and cannot alter procedural criteria arbitrarily.
• Protection of Legitimate Expectations: Strengthened the protection of individuals' legitimate expectations based on clear and consistent administrative practices.
• Administrative Accountability: Imposed stricter accountability on judicial and administrative bodies to adhere to procedural fairness and transparency.
• Future Judicial Appointments: Sets a precedent that any changes to the selection process must be made through proper channels and with due notice to affected parties.

Overall, the decision serves as a crucial check on administrative discretion, ensuring that deviations from established rules are not undertaken lightly and are subject to judicial scrutiny.

4.1 Doctrine of Legitimate Expectation

The doctrine of legitimate expectation protects individuals from abrupt and unfair changes in administrative procedures or policies that they reasonably relied upon. In simple terms, if a public authority has set clear rules or made promises, individuals have the right to expect those rules or promises to be honored unless there is a compelling reason to change them.

4.2 Ultra Vires

The term "ultra vires" comes from Latin, meaning "beyond the powers." An action is ultra vires if it exceeds the legal authority granted to an individual or institution. In this case, the High Court of Kerala acted beyond its authority by changing the selection criteria without proper amendment to the existing rules.

4.3 Article 14 of the Constitution

Article 14 ensures equality before the law and prohibits arbitrary actions by the state. It mandates that all individuals should be treated fairly and without discrimination by public authorities.

4.4 Principles of Good Administration

Good administration refers to the fair, transparent, and consistent operation of public authorities. It demands that decisions are made based on established rules and procedures, ensuring predictability and fairness in administrative actions.