MP HC Dismisses Bank Guard Applicants’ Appeal: Younger-Candidate Tie-Break Stands, And Bias Claims Cannot Be Heard Without Joining Officers

The appellants filed a writ appeal under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005, challenging the Single Judge’s order dated 13 March 2026 in W.P. No. 11006/2021.

The appeal was reported to be 21 days late; the Court condoned the delay.

The appellants submitted that their case was covered by the Division Bench’s decision in Rajpal Singh Jadon and Others v. Union of India and Others, W.A. No. 1919/2026, which concerned a bank Guard recruitment dispute involving the application of an age-based tie-break rule and allegations of bias in awarding marks.

Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005, provides the basis for the writ appeal.

Under the recruitment guidelines considered in Rajpal Singh Jadon, where two or more candidates receive identical marks, the younger candidate is ranked higher; applying a pre-existing, unchallenged tie-break criterion was not treated as improper or irrational.

The Court also relied on State of Bihar v. P.P. Sharma, 1992 Supp (1) SCC 222; Dr. J.N. Banavalikar v. Municipal Corporation of Delhi, AIR 1996 SC 326; and All India State Bank Officers’ Federation v. Union of India, JT 1996 (8) SC 550, for the principle that a person against whom mala fides or bias is alleged must be impleaded eo nomine and given an opportunity to respond.

The Division Bench accepted the appellants’ submission that their case was covered by Rajpal Singh Jadon and dismissed the appeal on that basis.

In the incorporated reasoning, the Court held that the younger-candidate tie-break rule had been set out in the applicable guidelines and was neither challenged nor shown to be irrational.

It further held that the allegations concerning the award of marks could not be considered because the relevant bank officers or recruitment-board members had not been impleaded in their personal capacity.

The Court dismissed the writ appeal in the terms of its judgment in Rajpal Singh Jadon. No further relief was granted.