Candidates Not At Fault: Supreme Court Orders TNPSC To Finalize Motor Vehicle Inspector Recruitment After Workshop Re-Verification

The Supreme Court upheld the Madras High Court's decision to conduct a fresh verification exercise regarding candidates' workshop experience, observing that administrative delays in granting retrospective renewals to automobile workshops should not penalize candidate-applicants who had no control over the process.

The Court disposed of a batch of civil appeals concerning the selection of 113 Motor Vehicle Inspectors-Grade II by the Tamil Nadu Public Service Commission (TNPSC).

Furthermore, the Apex Court affirmed that certificates issued by the Heads of Institutions were sufficient to claim benefits under the 'Persons Studied in Tamil Medium' (PSTM) quota, and directed the TNPSC to individually communicate evaluation marks to candidates falling outside the zone of consideration to ensure public transparency and bring finality to the protracted litigation.

The Bench of Justice JK Maheshwari and Justice Atul S Chandurkar observed, "The candidates who gained experience in such workshops which were shown to be approved on the concerned website or workshops whose applications for renewal were pending but were attending to Government vehicles could not have been prejudiced. After finding that the candidates were not at fault due to pendency of an application for renewal of approval and in absence of a definite policy in this matter, the direction to take a decision in the matter of grant/denial of renewal with retrospective effect was issued to the State Government...In our view, this direction results in providing a level playing field to all the candidates so that they are placed at par with each other. This would also result in more meritorious candidates being available for selection from a larger pool which would also be in public interest."

Senior Advocate Ravindra Srivastava, Senior Advocate S. Nagamuthu, Senior Advocate Uttara Babbar appeared for the Appellants, while Senior Advocate Menaka Guruswamy appeared for the Respondents.

Brief Facts of the Case

The dispute arose out of a recruitment process initiated by the Tamil Nadu Public Service Commission (TNPSC) for filling up vacancies to the post of Motor Vehicle Inspector-Grade II in the Tamil Nadu Transport Subordinate Services. The selection process comprised a written examination, certificate verification, and an oral test.

Initially, a list of successful candidates was published, and appointment orders were issued to several individuals. This selection was challenged before a learned Single Judge of the Madras High Court, who set aside the appointments and directed a fresh verification of the workshop experience certificates of all participating candidates. This view was largely upheld by the Division Bench and attained finality when the Special Leave Petition before the Supreme Court was dismissed.

Upon fresh verification, a revised list of candidates was published and called for oral interviews. This list was again challenged through multiple writ petitions. A learned Single Judge directed the TNPSC to complete the process and publish the final selection list.

On appeal, the Division Bench of the High Court observed that there was no uniform policy regarding the retrospective renewal of workshop approvals. It consequently directed the entire recruitment process to be redone after a fresh verification exercise by the Motor Vehicles Maintenance Department (MVMD). Aggrieved by various facets of the Division Bench's directions, three distinct groups of appellants—the initially selected candidates, the candidates included in the revised list, and the TNPSC—approached the Supreme Court.

Contentions of the Parties

The Appellants contended that since their names figured in the very first selection list, they ought not to have been excluded from the subsequent revised list. They argued that they possessed the requisite workshop experience from Government-approved workshops and satisfied all structural eligibility criteria. It was also argued that they were gravely prejudiced by the direction to undertake the entire selection process afresh. They submitted that verification of their experience certificates had already been scrupulously completed, and there was no legal justification to undo the steps already taken, especially since the recruitment had been pending for over six years. They asserted that placement in the revised list entitled them to the completion of the process based on that list alone.

The TNPSC contended that it possessed the independent power to verify whether an institution actually applied Tamil as a medium of instruction, and it was not bound to solely rely upon the certificates issued by the Heads of Institutions under the 'Persons Studied in Tamil Medium' (PSTM) quota. It argued that the High Court erred in directing the disclosure of marks of candidates who did not fall within the zone of consideration, relying on judicial precedents to assert that such information was confidential.

Observations of the Court

The Apex Court perused the counter-affidavits filed by the Director of the MVMD, which revealed that in compliance with the High Court's directions, retrospective approval had been granted to the concerned workshops. Upon fresh re-verification, the MVMD explicitly certified that these appellants indeed possessed more than the required one year of workshop experience.

The Court observed that since the technical defect regarding workshop approval stood cured and their experience was verified, these candidates were fully entitled to have their names considered for inclusion in the final select list.

The Court upheld the Division Bench's decision to re-run the recruitment process. The Court observed that the administrative delay or pendency of applications for renewal of workshop approvals was an issue over which the candidate-applicants had absolutely no control. Denying employment to candidates who gained experience at workshops that were otherwise functioning and attending to Government vehicles was arbitrary and discriminatory.

The Court further observed that the direction to conduct a fresh exercise provided a level playing field to all eligible candidates, which served the public interest by enlarging the pool of meritorious candidates. It clarified that placement in a provisional select list did not confer any vested right to appointment.

The Court observed, "Once it is found that a class of candidates had been deprived of proper participation in the selection process for no fault of theirs, the direction to undertake fresh process of recruitment does not deserve to be interfered with, especially when those candidates who were placed in the revised select list dated 28.04.2021 are also permitted to participate in the process of selection. No vested right could be claimed merely by placement in the revised select list, especially when the right of participation in the fresh selection process was not being taken away. We, therefore, do not find any justifiable legal ground to hold the conclusions recorded by the Division Bench that led to passing of the direction in paragraph 88(a) of the impugned judgment liable to be interfered with."

The Court observed that since the notification did not prescribe any additional requirement or stipulation to procure clearance from the Directorate of Technical Education, a certificate issued by the Head of the Institution certifying that the candidate studied in Tamil medium was sufficient and conclusive.

The Court noted that since the litigation had been prolonged for several years, disclosing the marks of candidates outside the zone of consideration was necessary to ensure transparency and bring quietus to the dispute. It observed that Courts are fully empowered to direct such disclosure when larger public interest demands it, provided answer sheets are not supplied.

"The Division Bench was of the view that the process of recruitment having been engaged in litigation for more than five years, it was in public interest that the marks of candidates be revealed so as to put a quietus to the said aspect. It further clarified in paragraphs 83 and 88(f) that the candidates would not be entitled to a copy of their answer sheets. We do not find any reason whatsoever to take a different view of the matter", the Court observed.

The Supreme Court upheld the essence of the impugned judgment of the Division Bench. It directed the TNPSC to expedite and conclude the entire selection process in accordance with the verification reports submitted by the MVMD and within the timelines designated by the High Court. All the Civil Appeals were accordingly disposed of.

Cause Title: S Senthil Kumaran Bose v. The State of Tamil Nadu & Ors. and other connected matters. [Neutral Citation: 2026 INSC 645]

Appearances:

Appellants:Senior Advocate Ravindra Srivastava, Senior Advocate S. Nagamuthu, Senior Advocate Uttara Babbar, Advocate on Record Rakesh K. Sharma, Advocate on Record M.p. Parthiban, Advocate on Record G. Indira, Advocate on Record Shilpa Liza George, Advocate on Record Raghunatha Sethupathy B, Advocate C. Paramsivam, Advocate Nishant Sharma, Advocate C. Paramasivam, Advocate Adviteeya, Advocate Boudhik Garg, Advocate Shruti Verma, Advocate Atharv Joshi, Advocate Kavya Verma, Advocate Khushi Rastogi, Advocate Priyaranjani Nagamuthu, Advocate Bilal Mansoor, Advocate Shreyas Kaushal, Advocate Balram Nayak, Advocate S. Geyolin Selvam, Advocate Alagiri K, Advocate Shivansh Sharma, Advocate Abhishek S, Advocate Km Vignesh Ram, Advocate Manoj V George, Advocate Akshita Agrawal, Advocate Ayush Shah, Advocate Ryana Mukherjee, Advocate Naveen Raj R, Advocate Nasib Masih, Advocate Azeem Samuel, Advocate Bharathimohan M., Advocate Gokulakrisnan, Advocate V. Swetha.

Respondents:Senior Advocate Menaka Guruswamy, Advocate on Record Neha Rathi, Advocate on Record Pranav Sachdeva, Advocate on Record Sabarish Subramanian, Advocate on Record G. Indira, Advocate on Record Sanjay Kumar Visen, Advocate on Record Sandeep Singh, Advocate on Record Vikas Mehta, Advocate N Subramaniyan, Advocate Kajal Giri, Advocate Mishra Divya Santosh, Advocate Khushboo Singhal, Advocate Somya Kumari, Advocate P Rohit Ram, Advocate Shaswati Parhi, Advocate Sanyam Jain, Advocate D. Sathiya, Advocate Mardiv Deslwa, Advocate Hitesh Kumar Sharma.

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