News Citation : 2026 LN (HC) 163 | 2026:CGHC:5491
January 31, 2026 : In a significant ruling on recruitment transparency, the High Court of Chhattisgarh has quashed the appointment of a candidate selected as Secretary (Contractual) of the Tatapani Micro Watershed Committee in Balrampur-Ramanujganj district, holding that the selection process was arbitrary and contrary to the terms of the advertisement.
The order was passed by Justice Parth Prateem Sahu in WPS No. 10253 of 2025, filed by 25-year-old Satyam Gupta, a resident of Gram Panchayat Nawadih in Balrampur-Ramanujganj district.
The dispute arose from an advertisement dated March 6, 2023, issued by the Deputy Director of Agriculture-cum-Project Manager, WCDC, Balrampur-Ramanujganj, inviting applications for the post of Secretary (Contractual) in various Micro Watershed Committees. For Tatapani Micro Watershed Committee, there was one unreserved post.
Gupta applied for the position and participated in the recruitment process. After scrutiny of applications, the department published a merit list of three candidates. Gupta’s name appeared at serial number one with 67.9 aggregate marks, including marks awarded for experience.
He later submitted all required documents, including an experience certificate issued by a private computer education institute.
However, months later, the authorities withheld the appointment process for Tatapani and another committee. When the final select list was eventually published, Gupta was shifted to the waiting list and Dilip Kumar Ekka was shown as the selected candidate. Notably, Ekka’s name had not appeared in the earlier merit list of three shortlisted candidates.
The State defended the selection, arguing that Ekka had secured 65.11 marks while Gupta had obtained only 62.9 in the final computation. According to the State, Gupta was not awarded marks for experience because his certificate was issued by a private institute rather than a government or semi-government body.
The Court examined the original merit list, which showed Gupta at the top and did not include Ekka among the three meritorious candidates considered for the single post. The State failed to explain how Ekka’s name surfaced directly in the final select list despite not featuring in the earlier merit list.
The Court observed that the advertisement did not require experience to be from a government or semi-government institution. It merely stated that preference would be given to candidates with computer experience. Since no such restriction was mentioned in the advertisement, the rejection of Gupta’s experience certificate on that ground was held unsustainable.
Relying on Supreme Court precedents, including Tej Prakash Pathak v. Rajasthan High Court (2024) and Bedanga Talukdar v. Saifudaullah Khan (2011), the Court reiterated that recruitment authorities must strictly adhere to the terms of the advertisement and cannot alter eligibility criteria mid-process unless expressly permitted.
The Court held that five marks previously awarded to Gupta for experience during scrutiny should be restored, bringing his total back to 67.9. In contrast, the selected candidate had 65.11 marks. The unexplained deviation from the original merit list and the exclusion of Gupta from selection were found to be arbitrary.
Setting aside the selection of Dilip Kumar Ekka, the Court directed the authorities to reconsider Gupta’s candidature based on the original merit list dated August 14, 2024, and to publish a fresh select list accordingly. The writ petition was allowed. The ruling reinforces the principle that public recruitment must remain transparent, rule-bound, and free from arbitrariness, particularly in contractual government appointments at the local level.
Case Reference : WPS No. 10253 of 2025, Satyam Gupta vs. State of Chhattisgarh & Others — Counsel for the Petitioner: Mr. Shrikant Kaushik, Advocate; Counsel for the State: Mr. Mayur Khandelwal, Panel Lawyer.
