Candidate lacking locus standi cannot challenge recruitment criteria if they fail to meet either standard.

AIIMS Rishikesh issued Advertisement No. 2017/129 on 02.09.2017 for various posts, including Medical Record Officer.

The recruitment was re-opened on 10.02.2023, and the applicant appeared for a computer-based test on 15.06.2023.

The Institute set qualifying marks at 50% for General candidates, 45% for OBC, and 40% for SC/ST.

The applicant, a General category candidate, scored 25.625%.

Respondents No. 2 to 5 were appointed based on the 50% criteria.

The applicant challenged these appointments and the results, alleging that a 2017 Governing Body decision required a minimum of 60% qualifying marks for the unreserved category.

1. Whether the selection and appointment of the private respondents were vitiated by the reduction of qualifying marks from 60% to 50% in violation of the Governing Body's decision.

2. Whether the applicant has the locus standi to challenge the selection criteria given his performance in the examination.

The court applied Section 19 of the Administrative Tribunals Act, 1985, which governs the filing of applications by "persons aggrieved".

It adhered to the principle that the authority conducting an examination has the competence to decide and uniformly apply qualifying marks based on administrative requirements, difficulty levels, and the urgency of recruitment.

Furthermore, the court applied the doctrine of locus standi, establishing that a candidate who fails to meet even the lower qualifying threshold (and would certainly fail under a higher threshold) lacks a "cause of action" to challenge the recruitment process.

The Tribunal found that the applicant failed to provide documentary evidence proving that the qualifying marks for the specific post of Medical Record Officer were ever fixed at 60%.

The minutes of the Governing Body meeting dated 05.12.2017, cited by the applicant, pertained specifically to the "Staff Nurse Grade-II" post and did not establish a general rule for all Group B & C posts.

The Tribunal reasoned that the competent authority has the discretion to adjust qualifying marks to ensure a sufficient pool of successful candidates.

Crucially, the court noted that since the applicant scored only 25.625%, he would not have qualified even if the marks were set at 60%; therefore, the change in criteria did not adversely affect his legal rights or interests.

It ruled that the applicant had no valid cause of action or locus standi to challenge the appointments, as the results of the recruitment did not prejudice him given his low score.

The Tribunal dismissed the Original Application and disposed of all pending MAs with no order as to costs.