A batch of 47 appeals before the Supreme Court of India, originating from judgments by the Rajasthan High Court. These appeals pertain to the recruitment process for the post of "Prabodhak" under the Rajasthan Panchayati Raj Prabodhak Service Rules, 2008. The appellants challenge the criteria for awarding bonus marks for teaching experience and the provision for age relaxation, arguing these rules are discriminatory and unconstitutional. The Supreme Court examines the legality of these provisions, considering the historical context, objectives of the recruitment process, and relevant legal precedents, ultimately concluding that the State's measures are neither discriminatory nor arbitrary, and dismisses the appeals.

1. Introduction

• Leave granted in SLP (Civil) Nos. 34742 and 34663 of 2013.
• Batch of 47 appeals involving common questions of law.
• Main appeal: Civil Appeal 7906 of 2010 (Mahesh Chand Bareth & Anr. vs. State of Rajasthan & Ors.).
• Appeals arise from judgments of the Division Bench of the High Court of Rajasthan.

2. Background Facts

• Shiksha Karmi Project launched in Rajasthan in 1987 with SIDA assistance.
• Aimed to provide education in remote rural areas using local youth as teachers.
• Successful in reaching children from disadvantaged communities.

3. Formulation of Rules

• Creation of regular cadre "Prabodhak" and "Senior Prabodhak" under amended Section 89 of the Rajasthan Panchayati Raj Act, 1994.
• Rajasthan Panchayati Raj Prabodhak Service Rules, 2008 framed under Section 102.
• Key provisions of the Rules, including definitions, methods of recruitment, age, academic and professional qualifications, and the selection process.

4. Guidelines and Advertisement

• Guidelines formulated on 27.05.2008 for selection of Prabodhak.
• Advertisement issued on 31.05.2008 for district-wise recruitment.
• Criteria for awarding bonus marks for teaching experience in government projects.

5. Contentions of Appellants

• Rule 13(v) providing age relaxation to certain categories is discriminatory and violative of Article 14.
• Administrative guidelines for bonus marks not publicly disclosed, changing the rules after the selection process began.
• Argued that the selection process should adhere strictly to the stipulated procedure.

6. Contentions of the State

• Historical background and objective of universalizing elementary education.
• Valuable experience of project teachers in far-flung areas.
• Legal prescription of guidelines for awarding marks for experience.
• All recruited Prabodhaks possessed the minimum educational qualifications.

7. Relevant Judgments Cited

• Bedanga Talukdar vs. Saifudaullah Khan & Ors., (2011) 12 SCC 85.
• State of Maharashtra vs. Raj Kumar, (1982) 3 SCC 313.

State's Contentions

• Experience from educational projects is relevant to the Prabodhak role.
• Age relaxation is provided to prevent excluding long-serving project workers.
• The measures are not discriminatory, supported by Satya Dev Bhagaur & Ors. Vs. The State of Rajasthan & Ors.

Questions for Consideration

1. Is Rule 13(v) discriminatory and contrary to Article 14 of the Constitution of India?
2. Is the award of bonus marks to project-employed applicants discriminatory and invalid?

Analysis of Rule 13

• Minimum and Maximum Age Requirement: Age limits for direct recruitment and various relaxations for different categories.
• Historical Context: Educational projects aimed to address absentee teachers in rural areas.
• Justification for Age Relaxation: Recognizing the experience and contributions of project workers.

Court's Findings on Rule 13(v)

• Non-Arbitrary Classification: Valid classification based on intelligible differentia between project-experienced applicants and others.
• Policy Decision: The government's decision on age relaxation is a matter of policy and not arbitrary.

Award of Bonus Marks

• Guidelines for Bonus Marks: Marks awarded based on experience, particularly for those in State-run projects.
• Justification: Similar to age relaxation, bonus marks recognize relevant project experience.

Supporting Precedents

• Union of India & Ors v. Shivbachan Rai: Affirmed the policy decision's validity.
• Srinivas K. Gouda v. Karnataka Institute of Medical Sciences: Supported differential marks for relevant experience.
• Satya Dev Bhagaur & Ors. v. The State of Rajasthan & Ors.: Upheld policy decisions with intelligible differentia.

Distinguishing Precedents

• Raj Kumar: No nexus between classification and objective; not applicable here.
• Kailash Chand Sharma: Impermissible discrimination without rational basis; not applicable here.
• Other Cases: Dayanand, Bedanga Talukdar, Archana, and Manoj Kumar Acharya; not applicable to the present facts.

Final Decision

• Non-discriminatory Practices: Age relaxation and bonus marks are not discriminatory.
• No Prejudice or Procedural Error: Guidelines were issued and applied uniformly.
• Conclusion: Appeals dismissed, upholding the State's measures.