Facts
The petitioners challenged TNPSC’s memorandum dated 7 May 2024 concerning selection under the Combined Civil Services Examination-II, notified on 23 February 2022.
Source reference: p. 1They had studied in Tamil medium in regular schools for some of their schooling, but completed relevant school examinations—including, for most petitioners, the 12th-standard examination—as private candidates in Tamil medium. Their candidature was not accepted under the Persons Studied in Tamil Medium (PSTM) category.
Source reference: p. 5–7Interim orders enabled consideration of some petitioners under PSTM, and certain candidates received provisional selection orders, which were withheld pending the petitions.
Source reference: p. 5–7The petitioners relied on earlier decisions recognising PSTM eligibility where an examination had been completed privately in Tamil medium.
Source reference: p. 3, 8–10Issues
Whether candidates who studied in Tamil medium in regular school but completed the 12th-standard examination privately in Tamil medium were eligible for PSTM preference.
Source reference: p. 2–4, 7–10Whether petitioners found eligible under PSTM were entitled to appointment, or only to consideration subject to their position within the zone of consideration.
Source reference: p. 10–11Law Applied
The Court considered the Tamil Nadu Appointment on Preferential Basis in the Services under the State of Persons Studied in Tamil Medium Act, 2010, which provides preferential appointment to persons who studied in Tamil medium, and Government Order G.O.(Ms.) No. 82, Human Resources Management (S) Department, dated 16 August 2021, concerning PSTM eligibility and proof of Tamil-medium study.
Source reference: p. 3–4, 9It also considered G.O.Ms. No. 16 dated 15 April 2025, which the respondent relied on to argue that private candidates were ineligible, but which the Court discussed in connection with direct admission between standards under the Right to Education Act.
Source reference: p. 4, 7Following Tamil Nadu Public Service Commission v. C. Dineshkumar, W.A. No. 2164 of 2024, and the subsequent Division Bench decisions in The Secretary v. S. Deepa, W.A.(MD) No. 2465 of 2024, and Tamil Nadu Public Service Commission v. R. Saravanan, W.A.(MD) No. 1743 of 2024, the Court treated private examination in Tamil medium, supported by competent-authority certification, as not by itself disqualifying a candidate from PSTM consideration.
Source reference: p. 3, 5, 8–10Reasoning
The Court found that the petitioners had taken the relevant examinations in Tamil medium and produced certificates confirming the medium of examination.
Source reference: p. 8Although they had not attended regular school in standards 11 and 12, the Court considered their earlier Tamil-medium schooling and the certified Tamil-medium examinations, and applied the approach in Dineshkumar, Deepa and Saravanan to hold that private study did not defeat PSTM eligibility.
Source reference: p. 8–10Eligibility did not, however, establish entitlement to appointment: the Court distinguished the three petitioners who were within the zone of consideration from the two who were not.
Source reference: p. 10–11Holding
The Court allowed the writ petitions and held that the petitioners were entitled to PSTM benefit.
It directed TNPSC to issue appointment orders within two weeks to M. Seetha, L. Selvi and M. Raja Mohamed, who were within the zone of consideration.
Source reference: p. 11D. Ezhilarasi and S. Thangaraj were held eligible for PSTM consideration but, as they were outside the zone of consideration, were not entitled to appointment.
Source reference: p. 11No costs were ordered, and the connected miscellaneous petitions were closed.
Source reference: p. 11Original Court PDF
M.SEETHAvsTHE SECRETARY
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