VidhiSangh

Supreme Court of India · 01/05/2025

R. RANJITH SINGH & ORS. versus THE STATE OF TAMIL NADU & ORS.

[2025] 5 S.C.R. 1778 · 2025 INSC 612

AI-generated headnote. Verify against the judgment before relying on it. Paragraph numbers refer to the judgment.

Summary

Directly recruited Sub-Inspectors of Police in Tamil Nadu challenged the placement of in-service (constabulary) candidates, selected against a 20% quota within the direct recruitment quota, en bloc above open-market recruits who had scored higher marks; this preference rested first on unnotified Government Orders of 1995, 1996 and 2009 and finally on a 2017 amendment to Rule 25(a) of the Tamil Nadu Police Subordinate Service Rules, 1955 made retrospective from 13.07.1995. The Supreme Court held that executive instructions cannot supplant statutory rules, struck down the 2017 seniority amendment and quashed the Government Order as violative of Articles 14, 16 and 21 while leaving the 20% reservation itself undisturbed, and directed that all gradation lists from 1995 be recast on the basis of marks, protecting promotions already made.

Issues

  1. Whether in-service candidates recruited against the 20% quota within the direct recruitment quota could be given seniority over open-market direct recruits on the strength of executive orders when Rule 25 of the 1955 Rules fixed seniority by rank in the select list.
  2. Whether the amendment to Rule 25(a) of the 1955 Rules by G.O. Ms. No. 868 dated 21.11.2017, granting such en bloc seniority with retrospective effect from 13.07.1995, is constitutionally valid.
  3. Whether the 2017 amendment providing 20% reservation in the direct recruitment quota for in-service candidates warrants interference.
  4. What relief should follow for the direct recruits and for in-service candidates already promoted on the basis of the earlier seniority lists.

Provisions considered

Held

Result

Appeals disposed of; G.O. Ms. No. 868 dated 21.11.2017 quashed and the amendment to Rule 25(a) struck down; all gradation lists for direct recruitment (including the 20% in-service candidates) to be recast on marks within 60 days; no reversion of officers already promoted, but no promotion of departmental candidates until the revised list; direct recruits found fit to get notional promotion, seniority and consequential benefits except back wages within two months of the revised list; future direct recruitment through one common examination with seniority by marks; no costs.

Judgment PDF: Supreme Court of India, [2025] 5 S.C.R. 1778.