Uttarakhand High Court

Employer-prescribed eligibility criteria for public service do not warrant judicial interference unless demonstrably unreasonable.

MANISHA SINGH vs STATE OF UTTARAKHAND

Uttarakhand High CourtJUDGMENT: April 08, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner, a resident of Uttar Pradesh who completed his entire education (High School, Intermediate, and D.El.Ed.) in that state, challenged a recruitment advertisement dated 07.11.2025

Source reference: para. 3

The advertisement, issued by the District Education Officer (Primary), Almora, for the post of Assistant Teacher, contained Clause ‘Ga,’ which required candidates to satisfy one of three conditions: (i) be a permanent resident/domicile of Uttarakhand, (ii) be registered with an employment exchange in Uttarakhand, or (iii) have passed 10th or 12th examinations from a school within Uttarakhand

Source reference: para. 3

The petitioner, meeting none of these criteria, sought to challenge the clause and requested a direction to the authorities not to reject his candidature

Source reference: para. 3

The State contended the conditions were based on statutory rules notified on 28.06.2019

Source reference: para. 4
02

Issues

Whether the eligibility conditions stipulated in Clause ‘Ga’ of the advertisement are legally sustainable and within the employer's prerogative to determine

Source reference: para. 6

Whether the Court should exercise its power of judicial review to interfere with recruitment conditions that the petitioner fails to meet under both the advertisement and the statutory rules

Source reference: para. 6
03

Law Applied

The Court primarily applied the statutory rules regarding eligibility for public services framed in 2010, as amended by the notification dated 28.06.2019

Source reference: para. 4, 6

It relied on the administrative law principle that an employer possesses the authority to determine specific eligibility conditions for appointment to public services

Source reference: para. 6

Furthermore, the Court applied the standard of judicial review, which dictates that administrative conditions in a recruitment process remain valid unless they are "so unreasonable" as to warrant judicial interference

Source reference: para. 6
04

Reasoning

The Court noted that while some conditions in the advertisement might not be explicitly referable to the 2019 amendment rules, the petitioner indisputably failed to satisfy the criteria set forth in both the advertisement and the applicable rules

Source reference: para. 6

The Court reasoned that the eligibility of a candidate must be strictly tested against the advertisement and the governing statutory framework

Source reference: para. 6

It further observed that the requirement for local residency, local registration, or local schooling was not "so unreasonable" as to justify the court’s intervention through judicial review

Source reference: para. 6

Because the petitioner did not meet any of the three alternative eligibility benchmarks determined by the employer, the Court found no legal basis to grant an exemption or strike down the clause

Source reference: para. 6
05

Holding

The Court held that every candidate for public service must meet the eligibility conditions determined by the employer and that the petitioner’s failure to meet any of the three prescribed conditions precluded his appointment

The Court found no grounds to interfere with the advertisement or the rules

Source reference: para. 6

Consequently, the writ petitions were dismissed

Source reference: para. 6
Uttarakhand High Court

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MANISHA SINGHvsSTATE OF UTTARAKHAND

Uttarakhand High Court · April 08, 2026

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