Summary
The Supreme Court upheld cancellation of the 2012 limited competitive examination recruitment to the IPS. Candidates had no vested appointment right, but cancellation still required fair, non-arbitrary public-interest reasons. Considering the combined effect of prolonged delay, older entrants, reduced vacancy percentage, remaining litigation and likely seniority disputes, the Court found the decision reasonable. Legitimate expectation did not compel completion and promissory estoppel was unavailable without detrimental change of position. The transferred cases became infructuous.
Issues
- Whether participation in the unfinished selection created an enforceable right to results or appointment.
- Whether cancellation met the requirements of fairness and public interest.
- Whether legitimate expectation or promissory estoppel required completion.
Held
- Even selection does not create an indefeasible appointment right; here results were undeclared and the selection process incomplete. Nevertheless the State’s decision not to fill vacancies had to be bona fide, justifiable and non-arbitrary. (¶¶ 14, 15, 16)
- Promissory estoppel failed because the candidates, already serving in police organisations or the armed forces, had not changed position to their detriment on the alleged promise. Legitimate expectation could arise without a vested right but could not prevent a reasoned, non-arbitrary policy change in public interest. (¶¶ 17, 18)
- The reasons for cancellation were assessed cumulatively rather than in isolation: delay of over five years, consequent age changes, unresolved challenges and likely seniority litigation, together with the fall in the vacancy percentage and resulting shortages in feeder organisations. The Court found the decision reasonable and free of mala fides or extraneous considerations. (¶¶ 19, 20, 21, 22, 23, 24, 25)
- The Court did not determine the merits of potential seniority disputes or finally adjudicate every challenge to the recruitment rules. On upholding cancellation, it treated the transferred cases as infructuous and rejected clarification, direction and intervention requests. (¶¶ 10, 20, 22, 26)
Result
Cancellation of the LCE recruitment upheld; transferred cases disposed of as infructuous. Clarification/direction and intervention applications rejected; pending applications disposed of.