TNPSC Must Apply TANGEDCO’s Ex-Apprentice Recruitment Policy Despite Its Omission From Field Assistant Notice: Madras HC Rules

The petitioners, trained ex-apprentices of the respondent Corporation, appeared in the written examination for Field Assistant posts under TNPSC Notification No. 13/2025.

After successful candidates were shortlisted for the physical test at a 1:3 ratio, they sought permission to participate and claimed preferential treatment under Section 22(1) of the Apprentices Act, 1961, and the Corporation’s policy in TANGEDCO Proceedings No. 8 dated 31.08.2017.

The TNPSC objected that the policy had not been included in the notification and could not be applied after recruitment commenced; the Corporation acknowledged that it had not informed TNPSC of the policy when making its requisition.

The petitioners sought, among other reliefs, to participate in the physical test notwithstanding the 1:3 shortlist ratio.

Section 22(1) of the Apprentices Act, 1961, as applied by the Court, requires an employer to formulate a policy for recruiting apprentices who have completed apprenticeship training in its establishment.

The Court treated TANGEDCO Proceedings No. 8 dated 31.08.2017, framed pursuant to that statutory obligation, as subordinate legislation governing recruitment to the Corporation’s posts.

It held that TNPSC was required to give effect to that applicable policy even though the recruitment notification did not refer to it; the policy did not, however, extend to dispensing with the stated 1:3 shortlisting ratio for the physical test.

The Court found that the 2017 policy applied to the Field Assistant post and was made to discharge the Corporation’s obligation under Section 22(1).

Because the policy was treated as subordinate legislation governing recruitment, the Corporation’s failure to notify TNPSC of it, and its omission from the recruitment notification, did not prevent its application.

The Court therefore rejected TNPSC’s contention that applying the policy would impermissibly change the recruitment terms mid-process.

However, the request to call the petitioners for the physical test outside the 1:3 ratio went beyond the policy’s scope and was not accepted.

The petitioners were not granted the requested exemption from the 1:3 shortlisting ratio.

Connected miscellaneous petitions were closed; no costs were awarded.