Summary
Candidates in the Uttar Pradesh police limited departmental promotion examination had to obtain at least 50 per cent in each of the four subjects. Combining two subjects in one paper did not permit their marks to be aggregated to satisfy that threshold. Reserved-category candidates could not obtain a relaxation that the State had not prescribed. Two cases mistakenly disposed of with direct-recruitment litigation were recalled to that limited extent, then independently dismissed on the same reasoning.
Issues
- Whether the minimum qualifying marks applied subject-wise or paper-wise.
- Whether reserved-category candidates could obtain unprescribed qualifying-mark relaxation.
- How the mistakenly clubbed transferred cases should be disposed of.
Provisions considered
- Rule 16(a)(i), Note 2, Uttar Pradesh Sub-Inspector and Inspector (Civil Police) Service Rules, 2008Required a minimum of 50 per cent marks in each subject, including each of the two 50-mark subjects placed in a common paper. (¶¶ 3, 12–13, 22)
Held
- The four subjects were separately delineated in the Rules. A common paper for subjects 3 and 4 could not override the express subject-wise qualifying requirement, and aggregate marks did not cure failure in an individual subject. (¶ 12–13)
- The State could prescribe a different or relaxed criterion for reserved categories, but had granted none. The Court could not supply that exception for candidates failing the existing threshold. (¶ 21–22)
- The earlier individual relief relied upon had not decided the controversy and expressly did not automatically operate as a precedent. (¶ 14)
- The departmental-examination transferred cases had been wrongly clubbed with direct-recruitment matters. The prior disposal was recalled only as to those cases; considered afresh, their reservation and relaxation claims failed for the same reasons. (¶ 23–30)
Result
All civil appeals dismissed without costs. Prior judgment recalled to the limited extent it disposed of Transferred Cases 287 and 297 of 2017; both transferred cases then considered afresh and dismissed. No relaxation or promotion directed.