The Supreme Court dismissed the appeal filed by Manoj Goyal, affirming the Rajasthan High Court’s decision to uphold the recruitment process for Additional District Judges conducted under the 2011 amended rules. The Court ruled that candidates who participate in a selection process without protest are estopped from challenging the rules after being declared unsuccessful. Furthermore, the Court held that the recruitment authority has the discretion to prescribe minimum qualifying marks for interviews to ensure the suitability of candidates for high judicial office, and that the Shetty Commission’s recommendations are guidelines rather than rigid statutory mandates.
Background
The appellant was an applicant for the post of Additional District Judge under the advocates’ quota in Rajasthan. Following a 2011 amendment to the Rajasthan Judicial Service Rules, 2010, a proviso was introduced requiring a minimum of 25% marks in the viva-voce (interview) for selection. Although the appellant secured a high aggregate score, he was disqualified because he obtained only 7 marks out of 30 in the interview, falling just short of the 7.5-mark (25%) threshold. The appellant challenged this rule and his subsequent disqualification, arguing that it violated Supreme Court directives based on the Shetty Commission Report.
Key Findings of the Supreme Court
- Doctrine of Estoppel: The Court held that the appellant, having participated in the recruitment process with full knowledge of the amended rules and without protest, was estopped from challenging those rules after failing to qualify.
- Status of Shetty Commission Recommendations: The Court clarified that the Shetty Commission’s recommendations, while important, are not rigid statutory mandates but are instead guidelines to be considered by High Courts. Once statutory rules are framed by a competent authority, the selection process must strictly follow those rules.
- Rationality of Viva-Voce Benchmarks: The Court determined that prescribing a 25% minimum benchmark for interviews is a rational administrative necessity to assess essential judicial qualities—such as alertness, resourcefulness, and leadership—that cannot be fully gauged by written examinations alone.
- Finality of Appointments: The Court noted that the recruitment process had been finalized in 2013 and the selected candidates had been serving for over a decade. Granting the appellant’s request for appointment and seniority would cause “profound injustice” to currently serving judicial officers and disrupt the established seniority matrix.
- Procedural Propriety: The Court upheld the High Court’s view that the challenge to the vires of the 2011 amendment had become academic because the proviso had been deleted by a subsequent amendment in 2017. It also affirmed that an earlier Supreme Court order had already declined to interfere with the finalized appointments, a position that could not be resurrected by the subsequent withdrawal of the petition.
Conclusion
The Supreme Court concluded that the appeal was devoid of merit and affirmed the Rajasthan High Court’s judgment, finding no grounds to invalidate the selection process or grant the appellant’s requested relief.
2026 INSC 699
Manoj Goyal v. Rajasthan High Court & Ors. (D.O.J. 14.07.2026)
