TITLE: VASHIST NARAYAN KUMAR V. THE STATE OF BIHAR & ORS.
CITATION: CIVIL APPEAL NO. 1 OF 2024 (ARISING OUT OF SLP (C) NO. 12230 OF 2023)
DECIDED ON: 2 JANUARY 2024
CORAM: JUSTICE J.K. MAHESHWARI, JUSTICE K.V. VISWANATHAN
Facts of the Case
Vashist Narayan Kumar met the requirements and passed the exams in order to pursue his dream of working as a police constable in Bihar. But his application was turned down because there was a small inconsistency in his birthdate—that is, between the information on his diploma and the information he entered in the online form. The State of Bihar defended the denial, claiming that any kind of false information called for such a measure. The High Court then affirmed the ruling, stating that no redress could be given. It was notable that the date of birth error had no effect on the selection process and that the State did not pursue criminal charges, indicating that the authorities did not consider the disparity to be serious.
Legal Provisions:
The eligibility criteria and selection process for the position of Police Constable in Bihar. Article 142 of the Constitution of India, granting the Supreme Court the power to pass any order necessary for doing complete justice in any cause or matter. Relevant case laws and precedents related to the acceptance or rejection of applications based on errors in documentation.
Issues Involved:
Whether a trivial error in the date of birth, which did not influence the selection process, should result in the rejection of a candidate’s application. Whether the State’s refusal to take criminal action indicates that the error was not considered serious by the State. Whether the rejection of the appellant’s application based on a minor discrepancy is justifiable under the law.
Court’s Observation and Analysis
In its analysis, the Supreme Court deviated from the positions held by the State and the High Court. The court highlighted the insignificance of the error and emphasised that the difference in birthdate had no effect on the selection procedure. Notably, the court emphasised that the appellant had not intentionally misrepresented anything, and that the State’s inaction in prosecuting the matter suggested that the disparity was not a major one. The ruling examined the difference between trivial and significant errors, holding that little errors—especially ones that do not give the applicant an advantage—should not be grounds for denial. The court emphasised that, in light of the circumstances surrounding the error, a fair and impartial approach is necessary. Making use of its authority under Article 142 of the Indian Constitution, the court ordered the State to consider Vashist Narayan Kumar as a successful applicant and to send out an appointment letter, even in cases where positions were not immediately filled. This strategy, which was backed by pertinent case laws and precedents, attempted to guarantee that justice and fairness triumphed despite procedural issues. Vashist Narayan Kumar’s appeal was ultimately successful because the court’s ruling demonstrated a dedication to maintaining fairness in the context of government job applications.
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Written by- Komal Goswami