Patna High Court
Employment and Labour LawAdministrative and Public Law

District-specific Employment Exchange registration cannot restrict equal access to employment opportunities.

Indrajeet Mali vs The Chief Manager, Punjab National Bank

Patna High CourtJUDGMENT: September 16, 20263 MIN READSOURCE JUDGMENT
District-specific Employment Exchange registration cannot restrict equal access to employment opportunities.. Indrajeet Mali vs The Chief Manager, Punjab National Bank. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, an OBC candidate, sought appointment as a part-time sweeper in Punjab National Bank pursuant to an advertisement published on 14 October 2021.

Source reference: p. 2, para. 2

Although he claimed to satisfy the eligibility criteria, he was not called for interview/document verification.

Source reference: p. 2, para. 2

The Bank’s merit list placed him tenth among OBC candidates, while there was only one OBC vacancy and only the first five candidates were called for document verification.

Source reference: p. 3, paras. 6–7

Relying on information obtained under the Right to Information Act, the petitioner alleged that the selection was restricted to candidates recommended by the Siwan Employment Exchange and that candidates from outside Siwan District had been considered.

Source reference: p. 2, para. 5; p. 3, para. 8

He filed I.A. No. 1 of 2026 seeking production of the complete selection records, quashing of the selection list, and impleadment of the selected candidate.

Source reference: p. 2, para. 3

The Bank and the State opposed the challenge, asserting that the petitioner was ranked tenth and therefore was not within the zone of candidates called for the selection process.

Source reference: p. 2, para. 4; p. 3, paras. 6–7
02

Issues

Whether the petitioner was unlawfully excluded from the interview/document-verification process despite being eligible for appointment as a part-time sweeper.

Source reference: p. 2, para. 2; p. 3, paras. 6–7

Whether the Bank’s preparation of the merit list and its decision to call only a limited number of candidates against the available vacancy were legally sustainable.

Source reference: p. 4, para. 8; p. 4, para. 11

Whether the alleged requirement of registration with the Siwan Employment Exchange, or the consideration of candidates registered outside Siwan District, invalidated the selection process and warranted production of records or quashing of the selection list.

Source reference: p. 3, paras. 5 and 9–10; p. 4, para. 11
03

Law Applied

The Court applied the principle that access to public employment cannot be subjected to an unduly restrictive territorial condition, such as requiring registration only with the employment exchange of the district where the vacancy arises, when such a condition would restrict equal opportunity in employment and conflict with constitutional norms governing access to public employment.

Source reference: p. 4, paras. 9–10

The Court further accepted that a recruiting authority may prepare a merit list in accordance with the notified selection criteria and limit the number of candidates called for subsequent stages based on the number of available vacancies, provided the process is not shown to be arbitrary or unlawful.

Source reference: p. 4, paras. 8 and 11
04

Reasoning

The Court found that the merit list had been prepared primarily on the basis of age, with older candidates placed higher in rank, and that the petitioner stood tenth in the OBC merit list.

Source reference: p. 4, para. 8

Since there was only one OBC vacancy, the Bank’s decision to call the first five candidates for document verification did not unlawfully exclude the petitioner; he fell outside the prescribed shortlist.

Source reference: p. 3, paras. 6–7; p. 4, para. 11

The RTI material relied upon by the petitioner showed only the candidates registered with the Siwan Employment Exchange and did not establish that the Bank was legally required to consider only candidates registered in Siwan.

Source reference: p. 4, paras. 8–10

The Court rejected the petitioner’s argument that employment-exchange registration had to be confined to the district where the vacancy arose, holding that such a restriction would impermissibly limit employment opportunities.

Source reference: p. 4, paras. 8–10

As no arbitrariness or illegality in the preparation of the merit list was demonstrated, the Court found no basis to call for the complete records or interfere with the selection.

Source reference: no citation
05

Holding

The Court held that the Bank had correctly prepared the merit list, in which the petitioner was ranked tenth, and had validly limited the candidates called for the next stage according to the available vacancy.

The writ petition was dismissed, and the Court declined to interfere with the selection process.

Source reference: p. 4, para. 11

I.A. No. 1 of 2026, seeking production of records, quashing of the selection list, and impleadment of the selected candidate, was also dismissed.

Source reference: p. 4, para. 11
Patna High Court

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Indrajeet MalivsThe Chief Manager, Punjab National Bank

Patna High Court · September 16, 2026

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