Introduction

The case of Salam Samarjeet Singh v. The High Court of Manipur at Imphal (2024 INSC 647) represents a pivotal moment in the adjudication of recruitment processes within the Indian judicial system. The petitioner, Salam Samarjeet Singh, contested the decision of the High Court of Manipur which declared him unsuccessful in the recruitment process for the position of District Judge (Entry Level) in the Manipur Judicial Service Grade-I. Central to the dispute were the procedures and criteria applied during the selection process, specifically concerning the imposition of a minimum qualifying mark in the viva-voce (interview) segment, which existed outside the originally prescribed recruitment rules.

The key issues revolved around whether executive instructions, in the form of a Full Court resolution, could override statutory recruitment rules and if such actions violated the principles of procedural fairness and legitimate expectation.

Summary of the Judgment

The Supreme Court of India, in a detailed examination, upheld the petitioner’s contention that the High Court of Manipur erred in imposing a 40% minimum qualifying mark for the viva-voce segment through a resolution, thereby violating the existing recruitment rules. The Court emphasized that statutory recruitment rules, as delineated in the Manipur Judicial Service (MJS) Rules, 2005, were clear in their evaluation criteria, which did not stipulate a minimum passing mark for the viva-voce but relied on cumulative grade values from both written and interview segments.

The Court found that the High Court's resolution to introduce a minimum cutoff was not only procedurally unfair but also contravened the principle of legitimate expectation, as candidates were recruited based on the rules available at the time of their application. Consequently, the Supreme Court directed that the petitioner be declared successful, ensuring adherence to the original recruitment framework.

Analysis

Precedents Cited

The judgment extensively referenced several key precedents to bolster the Court’s stance:

• Sivanandan C.T. v. High Court of Kerala (2023): Emphasized that High Courts cannot unilaterally alter recruitment criteria without statutory amendments.
• Kavita Kamboj v. High Court of Patiala & Hoshiarpur (2024): Highlighted that administrative instructions can supplement but not contravene established rules.
• Abhimeet Sinha v. High Court of Patna (2024): Reinforced that statutory rules take precedence over administrative resolutions in recruitment matters.
• All India Judges Association v. Union of India (2002): Established the framework for evaluating recruitment processes and the role of minimum qualifying criteria.

These precedents collectively underscored the inviolability of statutory recruitment rules and the limited scope of administrative modifications without legislative backing.

Legal Reasoning

The Supreme Court undertook a meticulous analysis, focusing on two primary issues:

1. Override of Statutory Rules: The Court held that the executive resolution imposing a 40% viva-voce cutoff was unconstitutional as it overstepped the authority granted under Article 234/309. The MJS Rules, 2005, explicitly outlined the evaluation mechanism without provisions for such cutoffs.
2. Frustration of Legitimate Expectation: The Court found that candidates, including the petitioner, were recruited under the clear terms of the existing rules. Introducing new criteria mid-process without prior notice breached the principle of legitimate expectation, as candidates were assured of the recruitment framework at the outset.

The Court emphasized that any deviation from established rules must undergo a proper amendment process, ensuring transparency and fairness, which was absent in this case.

Impact

This landmark judgment sets a precedential tone for future recruitment processes across India’s judicial and administrative frameworks. Key implications include:

• Reaffirmation of Statutory Fidelity: Administrative bodies are bound to strictly adhere to existing statutory rules and cannot introduce new criteria arbitrarily.
• Protection of Legitimate Expectations: Candidates have reinforced protection against unilateral changes in recruitment processes, ensuring fairness and predictability.
• Guidance for Judicial Bodies: High Courts and other judicial bodies are reminded of the constitutional limitations on their powers concerning recruitment modifications.

Overall, the decision fortifies the sanctity of recruitment rules, promoting equitable treatment of candidates and safeguarding against arbitrary administrative interventions.

Complex Concepts Simplified

Conclusion

The Supreme Court's decision in Salam Samarjeet Singh v. The High Court of Manipur serves as a critical affirmation of the indispensability of adhering to established statutory recruitment rules. By invalidating the High Court of Manipur's resolution to impose a new viva-voce cutoff, the Court underscored the primacy of clear, pre-defined rules in safeguarding procedural fairness and legitimate expectations of candidates.

This judgment not only rectifies the immediate injustice faced by the petitioner but also sets a robust precedent ensuring that future recruitment processes remain transparent, consistent, and anchored in the rule of law. It reinforces the judiciary's role in upholding constitutional mandates, thereby fostering trust and integrity within the judicial appointment mechanisms.