Patna High Court
Employment and Labour LawAdministrative and Public Law

Where service rules require no communication, resignation takes effect upon acceptance before withdrawal.

Sunil Kumar Tiwari vs The State of Bihar

Patna High CourtJUDGMENT: September 10, 20262 MIN READSOURCE JUDGMENT
Where service rules require no communication, resignation takes effect upon acceptance before withdrawal.. Sunil Kumar Tiwari vs The State of Bihar. Patna High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner was appointed as a School Teacher (Classes XI–XII) in Political Science at U.H.S. Mahisaur, Jandaha, Vaishali, pursuant to the BPSC recruitment process and joined service on 5 February 2024.

Source reference: pp. 2–3; para. 3

On 22 February 2024, citing his father’s illness and his own mental stress, he submitted his resignation to the Principal.

Source reference: pp. 3–4; para. 3

The competent authority accepted the resignation on 19 March 2024.

Source reference: pp. 10–12; paras. 7–8

On 2 May 2024, before being informed of the acceptance, the petitioner sought to withdraw his resignation and requested permission to rejoin service.

Source reference: pp. 4–5; para. 3
02

Issues

Whether acceptance of the petitioner’s resignation was required to be communicated to him for the resignation to become legally effective.

Source reference: pp. 15–17; paras. 12–14

Whether the petitioner could validly withdraw his resignation on 2 May 2024 after it had been accepted by the competent authority on 19 March 2024.

Source reference: pp. 15–17; paras. 12–14

Whether the petitioner was entitled to rejoin service and obtain the reliefs sought in the writ petition.

Source reference: p. 18; paras. 15–16
03

Law Applied

The Court applied Rule 10 of the Bihar State School Teacher (Appointment, Transfer, Disciplinary Proceedings and Service Conditions) Rules, 2023, under which the petitioner remained on probation during the initial two years and which contained no requirement that acceptance of resignation be communicated to the teacher.

Source reference: pp. 16–17; para. 13

Relying on The North Zone Cultural Centre & Anr. v. Vedpathi Dinesh Kumar, (2003) 5 SCC 455, and Shriram Manohar Bande v. Uktranti Mandal & Anr., 2024 SCC OnLine SC 647, the Court held that resignation becomes effective upon acceptance by the competent authority, even without communication, where the applicable rules do not mandate such communication.

Source reference: pp. 12–14; paras. 10–11

The Court distinguished S.D. Manohara v. Konkan Railway Corporation Ltd., 2024 (6) BLJ 57 (SC), where withdrawal was treated as valid in circumstances involving continued service and evidence indicating that the resignation had not attained finality.

Source reference: pp. 7–10, 15–16; paras. 6, 13
04

Reasoning

The Court found that the material chronology was undisputed: resignation on 22 February 2024, acceptance by the competent authority on 19 March 2024, and attempted withdrawal only on 2 May 2024.

Source reference: p. 15; para. 12

Since Rule 10 of the 2023 Rules did not require communication of acceptance, the resignation became operative on 19 March 2024 itself. Consequently, the petitioner’s later withdrawal could not undo the already effective resignation.

Source reference: pp. 16–17; paras. 13–14

The Court rejected reliance on S.D. Manohara, noting that the factual circumstances there included continued performance of duties and other conduct showing lack of finality, whereas no such circumstance was pleaded or established here.

Source reference: pp. 15–16; para. 13

The Court therefore upheld the respondents’ decision notwithstanding the absence of proven personal communication of the acceptance order.

Source reference: p. 17; para. 14
05

Holding

The Court held that, under the applicable 2023 Rules, communication of acceptance of resignation was not a legal prerequisite.

The petitioner’s resignation became effective upon its acceptance on 19 March 2024, before his attempted withdrawal on 2 May 2024; hence, the withdrawal was invalid and he had no right to rejoin service.

Source reference: pp. 16–17; paras. 13–15

The writ petition was dismissed, the acceptance order was not interfered with, and any pending application was disposed of.

Source reference: p. 18; paras. 15–17
Patna High Court

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Sunil Kumar TiwarivsThe State of Bihar

Patna High Court · September 10, 2026

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