Madhya Pradesh High Court
Administrative and Public LawEmployment and Labour Law

A candidate ranked next in an expired select list has no enforceable right to appointment.

Imran Khan vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: October 14, 20262 MIN READSOURCE JUDGMENT
A candidate ranked next in an expired select list has no enforceable right to appointment.. Imran Khan vs The State Of Madhya Pradesh. Madhya Pradesh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, who ranked second in a recruitment process for Section Officer (Administration), challenged the selected candidate’s claimed work experience as allegedly inaccurate.

Source reference: para. 2–4

After submitting objections and representations, and pursuing earlier writ proceedings, the petitioner was directed to submit a representation for decision.

Source reference: para. 2–4

The respondent authority rejected it on 24 February 2025, stating that the select list had expired.

Source reference: para. 2–4

The petitioner sought consideration for appointment; the respondent argued that the recruitment process had concluded and the list had expired in 2020.

Source reference: para. 2–4
02

Issues

1. Whether the petitioner could claim appointment or consideration for appointment solely because he ranked next in merit after the select list had expired

Source reference: para. 6

2. Whether the authority’s rejection of the petitioner’s representation was arbitrary or unlawful so as to warrant interference under Article 226

Source reference: paras. 7–8
03

Law Applied

Inclusion in a select list or waiting list does not, by itself, create an indefeasible right to appointment.

Source reference: para. 6

A writ of mandamus cannot issue in the absence of a subsisting select list or an enforceable legal obligation on the authority to appoint the claimant.

Source reference: para. 6

The Court considered its jurisdiction under Article 226 and noted the petitioner’s reliance on Articles 14 and 16, but identified no statutory provision or precedent as the basis for its decision.

Source reference: paras. 3, 6–7
04

Reasoning

The select list was valid for one year and had expired in 2020; the selected candidate had already been appointed and the recruitment process concluded.

Source reference: paras. 6–7

The subsequent discontinuation of that candidate’s contractual services did not create an appointment right in the petitioner.

Source reference: paras. 6–7

Further, the petitioner had not sought specific relief to set aside either the select list or the appointment.

Source reference: paras. 6–7

The Court found no material showing a statutory violation or an enforceable right, and held that the allegations concerning the selected candidate’s experience did not justify relief in the circumstances.

Source reference: paras. 6–7
05

Holding

The Court held that no ground existed to interfere with the order dated 24 February 2025.

The writ petition was dismissed as devoid of merit.

Source reference: para. 9
Madhya Pradesh High Court

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Imran KhanvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · October 14, 2026

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