Residence-based preference in local watershed projects is constitutionally valid and does not violate Article 16.

The three petitioners were appointed on a contractual basis in 2012 as Micro Watershed Secretaries under the Integrated Watershed Management Programme (IWMP) in District Koria.

In 2022, the State approved 387 contractual posts for the WDC-PMKSY 2.0 project, and an advertisement was issued on 02.03.2023.

The petitioners applied for these posts but challenged Clause-1 of the selection process.

This clause prescribed a minimum educational qualification of 12th pass but stipulated a preference for candidates who are residents of the specific Village/Gram Panchayat where the watershed project is situated.

The petitioners, who are not residents of the specific project Gram Panchayats despite their long-term contractual experience, alleged that this preference creates hostile discrimination and violates constitutional guarantees.

1. Whether the residency-based preference in Clause-1 of the selection process is arbitrary and violative of Articles 14 and 16 of the Constitution of India.

2. Whether the recruiting authority has the legal mandate to prescribe local residency as a preferential qualification based on the nature of the work.

The Court applied the principles of Article 14 (Equality before law) and Article 16 (Equality of opportunity in public employment) of the Constitution of India.

It relied on the doctrine of "Employer’s Prerogative," which establishes that the framing of eligibility conditions and criteria for appointment lies exclusively within the domain of the employer.

The Court further applied the "Rational Nexus" test, ensuring that any classification (such as local preference) must have a direct connection to the object sought to be achieved by the recruitment.

The Court reasoned that the post of Secretary, Microwatershed, requires duties such as continuous monitoring, close supervision, and a regular on-site presence at the grass-roots level.

It found that local residents are inherently better suited for these roles because they possess familiarity with the specific village landscape and Panchayat institutions, which is essential for effective coordination of the watershed project.

The Court noted that the impugned condition does not create an absolute bar against non-residents but merely provides a "preference."

Consequently, the Court held that since the criteria were founded on a rational basis directly linked to the effective implementation of the project, it did not constitute "hostile discrimination" or a violation of constitutional mandates.

The Court emphasized that candidates cannot demand that recruitment criteria be tailored to their personal convenience or experience.

The Court ruled that the recruitment condition possesses a rational nexus with the objective of efficient project management.

The final holding determined that the petition was devoid of merit, and the Court accordingly dismissed the writ petition.