Waitlisted candidates possess no indefeasible right to appointment after the recruitment panel’s validity period expires.

The applicants, belonging to OBC and UR categories, were placed in the waiting list for the post of Craft Instructor Welder (Gas & Electric), Post Code 99/14

The result notice dated 28.01.2020 stipulated that the waiting list would remain valid until 27.01.2021

A supplementary result declared on 16.03.2020 maintained the same validity period

Several selected candidates failed to join, leading to the cancellation of their candidatures on 02.03.2021, after the stipulated expiry of the panel

The applicants approached the Tribunal on 17.11.2021, seeking to set aside the result notice's validity limit, declare certain joined candidates unqualified, and seek appointment against the unfilled vacancies

1. Whether the inclusion of a candidate’s name in a select or waiting list confers an indefeasible right to appointment

2. Whether a waiting list panel can be operated or extended beyond its stipulated validity period to fill vacancies arising from non-joining candidates

3. Whether the respondents were obligated under Circular dated 22.10.2018 to issue appointment letters within a specific timeframe despite the panel's expiry

The court primarily applied the principle that mere inclusion in a select list does not confer an indefeasible right to appointment, as established in Rajasthan Public Service Commission, Ajmer v. Yati Jain & Ors. (2026 INSC 64)

Radhika T. v. Cochin University of Science and Technology & Ors. (2025)

The doctrine that a waiting list cannot act as a "perennial source of appointment" and cannot be used to fill vacancies that arise after the panel's expiry or notification, as seen in Rakhi Ray & Ors.

Section 19 of the Administrative Tribunals Act, 1985 regarding the timeframe for seeking judicial relief

The Tribunal observed that the panel’s validity undisputedly expired on 27.01.2021

Even if the supplementary result of March 2020 were viewed as an extension, the validity would have ceased by 15.03.2021

Since the applicants filed the Original Application only in November 2021—well after the panel had lapsed—and failed to specifically plead for an extension of the validity period, their claim was time-barred and lacked a legal basis

The Tribunal distinguished the applicants' reliance on the 2018 Circular, noting it was inapplicable because the applicants were already under consideration during the main result process and the panel had since expired

Connecting the facts to the "Rule of Law," the Tribunal reasoned that once a panel expires by efflux of time, the vacancies must generally be carried forward to subsequent advertisements (such as Advertisement No. 02/2023) rather than being filled from a dead list

The Tribunal answered that mere inclusion in a waitlist does not grant a vested right to appointment

The Tribunal concluded that since the panel’s validity period had expired prior to the filing of the application and the vacancies arose after said expiry, no directions for appointment could be issued

All pending miscellaneous applications were also disposed of with no order as to costs