Participation in recruitment confers no indefeasible right; State may cancel process for statutory conformity.

The petitioners, working as Assistant Grade-III clerks, applied for promotion to the post of Inspector (Legal Metrology) following a 2021 advertisement for a Departmental Promotion Competitive Examination

Under the Chhattisgarh Legal Metrology Recruitment Rules, 2013, the eligibility was a "Graduation Degree"

After initially being declared eligible, the petitioners were later deemed ineligible via an amended list in September 2022 because they lacked a degree with Physics, a condition not in the 2013 Rules at the time

Pursuant to an interim court order, the petitioners participated in the examination on December 17, 2022

On January 20, 2023, the State cancelled the entire examination process without declaring results

Subsequently, the State amended the 2013 Rules in June 2023 to mandate "Physics" as a subject to align with the Central Legal Metrology (General) Rules, 2011, and issued a fresh advertisement in August 2023

The petitioners challenged the cancellation and the retrospective application of the amended rules

1. Whether the cancellation of the Departmental Promotion Competitive Examination prior to the declaration of results was arbitrary or illegal

2. Whether the "rules of the game" were impermissibly changed midstream by introducing the "Physics" subject requirement after the commencement of the recruitment process

3. Whether mere participation in a recruitment examination confers a vested or indefeasible right upon the candidates to have the results declared or to be appointed

Rule 28 of the Legal Metrology (General) Rules, 2011, which mandates a B.Sc. with Physics or a Degree in Engineering as the minimum qualification for a Legal Metrology Officer

State Recruitment Rules are subordinate legislation and must conform to the parent Central Rules

The Constitution Bench decision in Shankarsan Dash v. Union of India, which established that successful candidates do not acquire an indefeasible right to be appointed

In K. Manjushree v. State of Andhra Pradesh, noting that while "rules of the game" cannot generally be changed midstream, statutory compliance with a parent act overrides this doctrine

The Court reasoned that the 2021 advertisement was fundamentally flawed as it prescribed "simple graduation," which contradicted the mandatory qualifications (Physics/Engineering) set by the Central Government under the 2011 Rules

Because the State Rules of 2013 were inconsistent with the parent Central framework, the State was duty-bound to rectify the error to prevent void appointments

The Court found that the cancellation of the December 2022 exam was a bona fide exercise of power aimed at statutory alignment rather than an arbitrary act

Regarding the "rules of the game" doctrine, the Court clarified that it cannot be invoked to compel the State to perpetuate an illegality or ignore binding Central legislation

Since the results were never declared and no select list was published, the petitioners’ status remained that of mere participants with no crystallized legal right

The Court concluded that the petitioners acquired no vested right to the declaration of results or promotion based on an erroneous eligibility criterion

The State’s actions in amending the 2013 Rules and issuing a fresh advertisement were upheld as necessary measures to ensure conformity with the Legal Metrology Act, 2009 and the 2011 Rules

All pending applications were disposed of without costs