Modifying assessment methodology mid-recruitment without altering eligibility criteria does not violate the "rules of the game" doctrine.

The recruitment for the post of Junior Engineer (E&M) in the Delhi Jal Board (DJB) originated from a 1991 recruitment cycle

Following prolonged litigation, the Central Administrative Tribunal (CAT) in T.A. No. 987/2009 and the Delhi High Court in W.P.(C) 4239/2013 directed that departmental/legacy candidates from the 1991 process be evaluated via interview only

Meanwhile, Recruitment Advertisement No. 02/2012 initially prescribed a two-tier written exam followed by an interview for fresh candidates

To maintain uniformity between the legacy candidates (governed by court orders) and fresh applicants, the DSSSB, with the Lieutenant Governor's approval, modified the scheme: a written screening test was used only for shortlisting, and the final merit list was prepared solely based on interview marks

The Petitioners, having participated in the screening and interview but remaining unsuccessful, challenged this deviation from the original advertisement.

The CAT dismissed their Original Applications on July 7, 2021

1. Whether the Respondents’ decision to prepare the final merit list based solely on interview marks, contrary to the original advertisement, amounted to an impermissible alteration of the "rules of the game" midstream

2. Whether the Petitioners, having participated in the selection process without protest, were estopped from challenging the methodology after being declared unsuccessful

3. Whether the administrative decision to adopt a uniform interview-based selection was justified by the necessity to comply with prior judicial directions

The court applied the "rules of the game" doctrine under Articles 14 and 16 of the Constitution, which prohibits arbitrary mid-process changes to recruitment criteria

It relied on State of Uttar Pradesh v. Karunesh Kumar & Ors. (2023), establishing that the doctrine primarily prevents changes that disqualify candidates or alter eligibility, rather than administrative adjustments to assessment modes

The court applied the principle of estoppel as settled in Madan Lal v. State of J&K (1995), K.H. Siraj v. High Court of Kerala (2006), and Om Prakash Shukla v. Akhilesh Kumar Shukla (1986), which holds that candidates cannot challenge a selection procedure after taking a "calculated chance" and failing

The Court reasoned that the deviation from the original advertisement was not arbitrary but a "practical necessity" to harmonize two distinct categories of candidates—legacy departmental candidates and fresh applicants

Since the legacy candidates were entitled to an interview-only evaluation by virtue of binding judicial orders, creating a combined merit list using two different methodologies was unfeasible

The Court noted that the revised scheme was transparently notified on November 27, 2014, prior to the screening test, and obtained necessary administrative approvals

Applying Karunesh Kumar, the Court found that no eligibility criteria were modified and no candidate was excluded; the change pertained only to the mode of assessment

Therefore, the administrative flexibility exercised by the DSSSB was reasonable

Additionally, the Petitioners’ failure to object contemporaneously while participating in the interview barred them from seeking relief post-result

The Court held that the selection process was fair, transparent, and necessitated by the unique legal complexities of the case

The Respondents’ actions did not constitute an impermissible change to the "rules of the game" as the change was disclosed beforehand and did not alter eligibility

The Court further emphasized that unsettling a decade-old recruitment process would defeat institutional stability

All pending applications were closed