Case Title: Union of India & Ors. vs. Manjurani Routray & Ors
Citation: CIVIL APPEAL No. 2299 OF 2010
Decided on: February 19, 2024
Coram: Justice J.K Maheshwari, Justice K.V Vishwanathan
In a recent judicial pronouncement, the Supreme Court of India upheld the importance of procedural integrity and adherence to legal principles in the case of Union of India & Ors. vs. Manjurani Routray & Ors. The judgment, rendered on February 19, 2024, addresses critical aspects of administrative law and underscores the significance of due process.
A Two Judge Bench of Justice J.K Maheshwari and Justice K.V Vishwanathan delved into nuanced exploration of administrative rules and their implications on promotions within the governmental framework, Justice J.K. Maheshwari observed that the High Court’s declaration of Rule 4(b) as ultra vires was unjustified due to the absence of specific pleading challenging the rule’s validity. He emphasized that for striking down laws or rules, specific grounds for challenge and relief must be pleaded. Since the respondent did not challenge Rule 4(b) and did not seek relief against it, the High Court’s action was deemed inappropriate.
Background:
The case originates from the filing of Original Application No. 148 of 2001 before the Central Administrative Tribunal (CAT) by respondent, Manjurani Routray, who was working as a Principal System Analyst (Scientist D) in the National Informatics Centre, Cuttack. The essence of the dispute revolves around the denial of her promotion to the post of ‘Scientist E’ despite fulfilling the eligibility criteria as per the FCS.
Judicial History of the Case:
The matter progressed through various legal stages, including the CAT and subsequently the High Court, with respondent no. 1 seeking redressal for the denial of promotion. The CAT, in its order dated May 4, 2005, directed the department to elucidate why respondent no. 1 was not considered suitable for promotion despite her commendable performance. However, the High Court, in its judgment dated September 26, 2008, went further, declaring Rule 4(b) of the Ministry of Information Technology (In situ promotion under Flexible Complementing Scheme) Rules, 1998, as invalid.
Courts Judgement and Analysis:
The Supreme Court, while examining the appeal, scrutinized the legal aspects and factual matrix of the case. In its judgment, the Court observed the absence of grounds challenging the vires of Rule 4(b) of Ministry of Information Technology (in-situ Promotion under Flexible Complementing Scheme) Rules 1998, and the lack of specific relief sought in this regard. The Court emphasized the necessity for proper pleading to challenge statutory provisions and highlighted the fundamental principle that such challenges must be clearly articulated to afford the opposing party an opportunity to respond.
“It is a trite law that for striking down the provisions of law or for declaring any rules as ultra vires, specific pleading to challenge the rules and asking of such relief ought to be made, that is conspicuously missing in the present case.”
This excerpt encapsulates the Court’s emphasis on procedural propriety and the importance of due process in legal proceedings.
The judgment serves as a beacon highlighting the significance of adherence to procedural norms and the necessity for clarity in pleading legal contentions. By setting aside the High Court’s declaration regarding the invalidity of Rule 4(b), the Supreme Court reaffirmed the principle that judicial pronouncements must be anchored in meticulous legal reasoning and factual analysis.
In conclusion, the case of UNION OF INDIA & ORS. vs. MANJURANI ROUTRAY & ORS. underscores the vital importance of procedural regularity and specificity in legal proceedings. The Supreme Court’s examination and subsequent ruling provide invaluable insights into the nuances of administrative law and statutory interpretation. This judgment stands as a testament to the judiciary’s commitment to upholding the principles of fairness, justice, and due process.
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Written by- Aditi
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