Summary
An unsuccessful officer challenged selection of non-State Civil Service officers to the IAS, obtaining a High Court direction for his individual recommendation and assessment. The Supreme Court found no bias, mala fides, arbitrariness or serious breach in the committees’ selection. Serial placement in preliminary lists was irrelevant, and a minister’s approval power did not authorise adding an independent recommendation. The Court restored the existing selection by setting aside the High Court judgment.
Issues
- What limits applied to judicial review of expert selection committees.
- Whether serial placement, the minister’s addition of a name or absence of recorded reasons invalidated this selection.
- Whether the High Court could direct recommendation of one particular candidate.
Held
- Courts do not reassess comparative merit as appellate selection bodies; review concerns serious statutory violation, bias, mala fides or arbitrariness. (¶¶ 5.1, 5.2, 5.3)
- Serial placement in the departmental and screening lists had no relevance to selection. The minister’s power to approve recommendations did not permit adding a third name independently when only two recommendations were invited. (¶¶ 9, 9.1)
- A duly constituted selection committee was not required to disclose reasons absent a governing rule, regulation or guideline requiring it, although procedural fairness remained necessary. (¶¶ 9.2, 9.3)
- The earlier recommendation had been returned as non-compliant, rather than remaining undecided. No arbitrariness or bias in the later departmental selection was established. (¶¶ 10.1, 10.2)
- Even if arbitrariness had been found, the permissible course was reassessment of all candidates, rather than a judicial direction to recommend one named candidate. No reconsideration was warranted on these facts. (¶ 11)
Result
Appeals allowed and the High Court judgment set aside. No reconsideration of the seventeen candidates or interference with IAS appointments for Selection Year 2014 was warranted.