Different service requirements for direct recruits and promotees are valid when prior experience justifies the distinction.

The petitioners challenged the sixth proviso to Annexure III of the Tamil Nadu Revenue Subordinate Service Rules, which required directly recruited Assistants to complete five years of service to be eligible for inclusion in the Deputy Tahsildar panel.

Promotee Assistants, by contrast, were required to complete four years in the Assistant cadre, after having served as Junior Assistants.

The State maintained that promotee Assistants had prior departmental experience, while the five-year period for direct recruits incorporated prescribed training and field exposure.

1. Whether requiring directly recruited Assistants to complete five years of service, while requiring promotee Assistants to complete four years in the Assistant cadre, violates Articles 14 and 16 of the Constitution

2. Whether the Court could interfere with the prescribed service and training requirements for eligibility for promotion to Deputy Tahsildar

The sixth proviso to Annexure III of the Tamil Nadu Revenue Subordinate Service Rules prescribes a five-year service requirement for directly recruited Assistants to be considered for the Deputy Tahsildar panel, subject to the prescribed tests and training.

The Court applied the principle that prescribing qualifications and experience is generally within the employer’s domain and may be reviewed where the prescription violates the governing law or the Constitution.

It relied on T.K. Ponnusamy v. Government of Tamil Nadu (1994) Supp (3) SCC 376, distinguishing it on its facts, and on the qualification-setting principles quoted from Md. Firoz Mansuri v. State of Bihar, 2026 SCC OnLine SC 88.

For Article 14 purposes, a distinction between groups is permissible where it rests on an intelligible differentia relevant to the requirement in question.

The Court accepted the State’s explanation that promotee Assistants had already gained experience in the Revenue Department as Junior Assistants, whereas directly recruited Assistants required additional training and field exposure.

It found that the five-year period for direct recruits included prescribed training and service as a Firkha Revenue Inspector, while promotees’ prior departmental experience justified the one-year concession.

The Court therefore treated the two recruitment streams as distinct for the purpose of prescribing experience, found a rational basis for the difference, and held that the requirement was neither arbitrary nor discriminatory.

It also declined to substitute its judgment for the Government’s assessment of the experience needed for the Deputy Tahsildar post.

It dismissed all the writ petitions and closed the connected miscellaneous petitions, with no order as to costs.