Absence of predefined objective criteria and transparent selection norms renders public recruitment arbitrary and invalid.

In December 2012, Eastern Railway issued a notification for sports quota recruitment (Pay Band-1, Grade Pay Rs. 1800/-) for the year 2012-13, including one vacancy for Kabaddi (Men).

The applicant, a Kabaddi player, applied and was found eligible for trials.

Following trials and an interview, the Recruitment Committee declared him "unsuitable" after awarding him 57 out of 100 marks, asserting that the qualifying threshold was 60 marks.

In O.A. 1255/2013, the Tribunal directed a re-examination, and a subsequent appeal by the Railways to the Calcutta High Court (WPCT 13/2022) was dismissed with costs.

On 13.03.2020, the Principal Chief Personnel Officer (PCPO) issued a speaking order again rejecting the applicant’s claim, citing the committee's discretion and the expiration of the financial year quota.

The applicant challenged this rejection in the instant O.A.

1. Whether the selection process was arbitrary and flawed due to the absence of pre-defined norms, marking parameters, or qualifying standards in the recruitment notification.

2. Whether the rejection of the applicant’s candidature was legally sustainable when the "60-mark" qualifying criterion was applied at the discretion of the committee without statutory or regulatory backing.

The Tribunal exercised jurisdiction under Section 19 of the Administrative Tribunal Act, 1985.

The court scrutinized the application of Railway Board Circular RBE No. 189(B)/2010, which governs the recruitment of sportspersons.

The court applied the constitutional and administrative law principle that public employment processes must be transparent, non-arbitrary, and based on pre-defined, communicated criteria.

The court relied on the doctrine that administrative discretion in selection must be guided by objective standards rather than the subjective whims of a committee.

The Tribunal found that the selection process was "completely flawed" because neither the employment notification nor the Railway Board guidelines specified the modalities for the selection test.

Specifically, the notification lacked details on how marks were to be allocated across parameters or what constituted the minimum qualifying marks.

The respondents admitted that there were no specific guidelines for the distribution of marks, yet the Recruitment Committee unilaterally fixed a 60-mark qualifying limit to reject the applicant.

The Tribunal reasoned that in the absence of objective standards, the committee exercised unfettered and arbitrary discretion.

It emphasized that for government appointments, the modalities, norms, and standards must be fixed and communicated to applicants well in advance to satisfy the requirements of fairness and transparency.

Consequently, the rejection based on such an opaque process could not be justified.

It quashed and set aside the PCPO’s order dated 13.03.2020.

The O.A. was allowed, and the competent respondent authority was directed to issue appropriate orders (regarding the applicant's appointment/relief) within two months of the receipt of the certified copy of the order.

No costs were awarded.