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
- Whether later litigants could claim recalculation and appointment under the earlier bonus-marks rulings.
- Whether favourable final orders in other individual cases supplied a precedent or parity claim.
- How final individual judgments and pending proceedings should be treated.
Held
- The earlier rulings protected appointments made through 17 November 1999 and confined recalculation relief to candidates who had approached the High Court before 18 November 1999. Later litigants could not enlarge those directions. (¶¶ 6–10, 13)
- Parity with wrongly granted relief and the existence of vacancies did not create entitlement contrary to binding Supreme Court directions. Impleadment applications seeking that benefit were dismissed. (¶ 10–11)
- Res judicata bound parties to final individual decisions, while precedent governed the legal issue generally. A delay-based appellate or SLP dismissal did not establish a contrary ratio for other candidates. (¶ 11–12)
- The no-relief rule for petitions filed after 17 November 1999 was subject to final individual cases governed by res judicata. Other pending petitions and appeals were to follow the specified precedents and this ruling, subject to justified and satisfactorily explained condonation of delay. (¶ 13)
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.