CAT - Allahabad

A candidate ranked outside the prescribed merit panel limit has no enforceable right to appointment.

PUSHPA DEVI vs M/o Communications

CAT - AllahabadJUDGMENT: March 25, 20263 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The respondents issued a notification on February 15, 2013, for the engagement of a Gramin Dak Sevak Branch Post Master (GDS BPM) at Bankagaon

Source reference: p. 2, 5

A total of 73 applications were received, and a merit list was prepared based on High School marks, where the applicant was placed at Serial No. 6

Source reference: p. 3, 5-6

The candidate at Serial No. 1 was disqualified due to invalid educational credentials, and the candidate at Serial No. 2, Sri Abhay Pratap Singh, was offered the position on June 9, 2014

Source reference: p. 3, 6-7

After the selected candidate declined the offer on August 20, 2014, the post remained vacant

Source reference: p. 2, 3

The applicant filed a representation seeking appointment, which was rejected by a reasoned order on July 6, 2015

Source reference: p. 1, 3-4

The respondents contended that no mandatory "select panel" had been drawn and that, per Directorate instructions dated May 28, 2015, all recruitment processes not finalized by June 30, 2015, were to be cancelled

Source reference: p. 3, 8
02

Issues

1. Whether the applicant, placed at Serial No. 6 in the merit list, had an enforceable legal right to appointment following the refusal of the selected candidate

Source reference: p. 3, 7

2. Whether the respondents’ failure to prepare a select panel in the ratio of 1:5, as per prevailing instructions, entitled the applicant to be considered for the vacancy

Source reference: p. 6-7
03

Law Applied

The court primarily applied the GDS (Conduct Engagement) Rules, 2011, which govern the recruitment process for postal sevaks

Source reference: p. 3

It relied on the Postal Directorate Letter No. 19-14/2010-GDS dated June 25, 2010, which mandates the drawing of a select panel of five candidates for a single vacancy to be operated in the event of refusal or resignation by the first candidate

Source reference: p. 6

Furthermore, the court adhered to the Directorate instructions dated May 28, 2015, which required the cancellation of all pending recruitment notifications that were not completed by the stipulated deadline of June 30, 2015

Source reference: p. 3, 8
04

Reasoning

The court examined the comparative merit chart and observed that the applicant was positioned at Serial No. 6 with 74.66% marks

Source reference: p. 7-8

Under the applicable Directorate instructions of June 25, 2010, a select panel is limited to only five candidates per vacancy

Source reference: p. 6, 7

The court reasoned that even if the respondents had strictly followed the procedural requirement to prepare a formal select panel, the applicant would not have been included as her merit position fell outside the top five

Source reference: p. 7-8

The applicant's claim that candidates at Serial Nos. 3, 4, and 5 were ineligible was dismissed as unsubstantiated hearsay, as no evidence was provided to prove their disqualification

Source reference: p. 7

Consequently, the court found that the applicant lacked the locus standi to challenge the vacancy's closure, especially since the recruitment process was officially terminated by the Directorate's policy decision to cancel all unfinalized appointments by June 2015

Source reference: p. 8
05

Holding

The Tribunal held that the applicant had no enforceable claim to the post because her merit position (Serial No. 6) placed her outside the mandatory zone of consideration for the five-member select panel

The court answered both issues in the negative, finding no arbitrariness or violation of rules by the respondents

Source reference: p. 8

The Original Application was dismissed, and all pending miscellaneous applications were closed with no order as to costs

Source reference: p. 8
CAT - Allahabad

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PUSHPA DEVIvsM/o Communications

CAT - Allahabad · March 25, 2026

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