Rules of a recruitment process cannot be altered retrospectively after its substantial completion to divest accrued rights.

The petitioners were initially appointed as Local Bodies Teachers under the Bihar Panchayat Primary Teacher Rules, 2012

In 2023, the State framed the "Bihar School Exclusive Teachers Rules, 2023," requiring local bodies teachers to pass a "competency test" to join a new district cadre with better service conditions

Per the Unamended Rules, candidates provided three district preferences, and allotment was based on merit

The petitioners qualified the test, were allotted districts based on their merit/choice, underwent document verification, and received provisional appointment letters on 20.11.2024

However, on 19.12.2024, the State notified the "Amendment Rules, 2024," deleting the district choice provision and requiring teachers to be posted in their original pre-existing schools

Consequently, the Director of Primary Education issued Memo No. 2036 on 21.12.2024, cancelling the petitioners' provisional appointment letters and directing them to rejoin their original schools

1. Whether the respondent authorities were legally justified in applying the "Amendment Rules of 2024" retrospectively to the petitioners’ cases after the selection process under the Unamended Rules was substantially complete

2. Whether the cancellation of provisional appointment letters and the change in posting policy constitute an arbitrary change to the "rules of the game" mid-way through the process in violation of Articles 14 and 16 of the Constitution

3. Whether the petitioners acquired a vested right or legitimate expectation to be posted in their allotted districts based on the merit-cum-choice results

The Court applied the constitutional mandate of fairness and non-arbitrariness under Articles 14 and 16

It relied on the doctrine that the "rules of the game" cannot be changed after the commencement and substantial completion of a selection process

The Court invoked the presumption of prospectivity in statutory interpretation, holding that a statute or rule is prospective unless it expressly or by necessary implication provides for retrospectivity

It further applied the principle of "Legitimate Expectation" as established in Abhay Kumar Patel & Ors. v. State of Bihar & Ors. (2026), which protects candidates from fundamental changes to merit-based placement criteria after the initiation of recruitment

The Court reasoned that by the time the Amendment Rules, 2024 came into force, the petitioners had already qualified the test, been allotted districts on merit, and received provisional appointment letters

Such a process ripened into a crystallized entitlement or, at minimum, a legitimate expectation that could not be defeated by subsequent executive action

The Court observed that the 2024 Amendment contained no express language giving it retrospective effect to nullify concluded processes

The State’s argument regarding "administrative convenience" was rejected, as it cannot override statutory provisions or the constitutional requirement for fairness in public employment

The Court emphasized that district allotment was a substantive component of the selection mechanism, and depriving successful candidates of this merit-based benefit after the process concluded was arbitrary and discriminatory

The Court allowed the writ petitions and quashed Memo No. 2036 dated 21.12.2024 and subsequent provisional appointment letters issued under the 2024 Amendment, directing the respondents to restore the original provisional appointment letters dated 20.11.2024 and complete the posting of the petitioners in their originally allotted districts within six weeks