VidhiSangh

Supreme Court of India · 30/04/2019

THE STATE OF RAJASTHAN versus NEMI CHAND MAHELA AND OTHERS

[2019] 18 S.C.R. 995 · 2019 INSC 588

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Summary

Candidates who had not filed writ petitions by 17 November 1999 were not entitled to Rajasthan teacher appointments through recalculation excluding unconstitutional residence-based bonus marks. The limited prospective-overruling relief in Kailash Chand Sharma, clarified in Manmohan Sharma, could not be enlarged through parity or vacancies. Final individual judgments protected by res judicata remained distinct from binding precedent; delay-based dismissal of an appeal or SLP did not create a contrary ratio.

Issues

  1. Whether later litigants could claim recalculation and appointment under the earlier bonus-marks rulings.
  2. Whether favourable final orders in other individual cases supplied a precedent or parity claim.
  3. How final individual judgments and pending proceedings should be treated.

Held

Result

Appeals and pending applications disposed of on the stated directions. Candidates who had not filed writ petitions by 17 November 1999 denied appointment through bonus-mark recalculation, except individual cases protected by res judicata; pending proceedings to follow the binding rulings.

Judgment PDF: Supreme Court of India, [2019] 18 S.C.R. 995.