Facts
The applicant, a highly qualified Neurologist, challenged the rank list [Annexure A1] published on 30.06.2023 for the permanent post of Assistant Professor (Neurology) at the Sree Chitra Tirunal Institute (SCTIMST)
Source reference: p. 2-4The applicant contended that the selection process was flawed because: (i) despite 17 candidates being shortlisted for 2 unreserved vacancies, no written screening test was conducted as per the notification; (ii) Respondents 5 and 6 lacked the requisite post-DM experience; and (iii) the interview evaluation was biased, evidenced by uniform marks awarded by multiple evaluators
Source reference: p. 5-6, 11-12, 16The respondents maintained that a written test was only mandatory if candidates exceeded 12 per vacancy and that the evaluation was fair and independent
Source reference: p. 8-9Issues
1. Whether the failure to conduct a written screening test when 17 candidates were shortlisted violated the selection process prescribed in Annexure A6 notification and the Standard Operating Procedure (SOP)
Source reference: p. 7 / para. 112. Whether the selection of candidates based solely on an interview is legally permissible for high-level academic positions
Source reference: p. 10 / para. 163. Whether the evaluation process was tainted by bias or lack of independent assessment due to the uniformity of marks assigned by the evaluators
Source reference: p. 15-16 / para. 23Law Applied
The Tribunal applied the principle that "rules of the game" cannot be changed after the process begins, as established in Maharashtra SRTC v. Rajendra Bhimrao Mandve [(2001) 10 SCC 51]
Source reference: p. 11Regarding selection by interview, it relied on Kiran Gupta v. State of UP [(2000) 7 SCC 719], which clarified that for higher posts requiring mature personalities, an interview can be the sole criterion, distinguishing the earlier student-admission focused ruling in Ajay Hasia v. Khalid Mujib [(1981) 1 SCC 722]
Source reference: p. 10-11The Tribunal also adhered to the principle of judicial restraint in reviewing the technical evaluations of expert selection committees
Source reference: p. 19-20Reasoning
The Tribunal found that Clause 10 of the notification and the Institute’s General Body resolution [Annexure R1(a)] implied that the "12-candidate rule" for written tests applies per vacancy; thus, with 17 candidates for 2 vacancies, the ratio was below the threshold for a mandatory exam
Source reference: p. 9-10On the issue of experience, the Tribunal noted that all selected candidates possessed the essential DM qualification and that "desirable" criteria did not override essential eligibility
Source reference: p. 14Regarding the "suspicious" uniformity in marks, the Tribunal conducted an in-camera inspection of the original evaluation sheets. It discovered that evaluators had indeed assessed candidates independently, and that minor variations in specific heads—not visible in the RTI summaries—had tilted the final rankings
Source reference: p. 18The Tribunal concluded that uniformity among experts when assessing high-caliber candidates is not evidence of bias but rather a consensus of professional judgment
Source reference: p. 19Holding
The Tribunal held that the selection process was valid and conducted in accordance with the notification and governing rules. The direct answers to the issues were: (i) No written test was required as the candidate-to-vacancy ratio did not exceed 12:1; (ii) Selection by interview is legally sound for Assistant Professor roles; and (iii) No evidence of mala fides or lack of independent evaluation was found following a records review
The Original Application was dismissed
Source reference: p. 20Original Court PDF
Dr Harikrishnan RvsSree Chitra Tirunal Institute for Medical Sciences and Technology, Trivandrum
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