Shailendra Kumar Patel vs State of Chhattisgarh & Ors.

This case addresses a crucial conflict between the selection authority of the Public Service Commission and the hiring power of the government. Dr. Shailendra Kumar Patel was selected by the Chhattisgarh Public Service Commission (CGPSC) for the post of University Registrar in 2021. Instead of issuing his appointment letter, the state government formed a special committee that re-examined his teaching experience and declared him ineligible. Patel challenged this, but the High Court ruled in favor of the State, stating that selection does not guarantee a job. The Supreme Court clarified that while a selected candidate does not have an absolute right to be appointed, the government cannot act arbitrarily. Under Rule 10 of the Chhattisgarh State Universities Service Rules, 1983, the Commission's decision on a candidate’s eligibility is final. The Court held that the government's role is limited to verifying the genuineness of documents (like checking for fraud or fake certificates) and addressing obvious errors. The government cannot conduct an exhaustive, independent inquiry to reassess a candidate's eligibility after the Commission's approval. If the government has doubts, it must refer the matter back to the Commission rather than taking independent action. Consequently, the Supreme Court set aside the High Court's judgments, declared Patel eligible, and directed the state to appoint him as Registrar with full service benefits.

Dr. Shailendra Kumar Patel was selected by the Chhattisgarh Public Service Commission for the post of Registrar in 2021. However, instead of appointing him, the State Government formed an inquiry committee that declared him ineligible due to a lack of experience. He challenged this action, but the High Court upheld the State’s decision, forcing him to appeal to the Supreme Court.

The Supreme Court allowed the appeal and ordered the State Government to appoint the appellant as Registrar in a State University within three weeks. It ruled that the government cannot conduct a fresh, detailed inquiry into a candidate's eligibility if the Public Service Commission has already finalized it. The appellant is also entitled to all service benefits and seniority from the date his peers were appointed.

This judgment protects job seekers from arbitrary and unfair delays by government departments after clearing official competitive exams. It establishes that while the government can check if certificates are fake, it cannot overrule the Public Service Commission's expert decision on a candidate's qualifications.