Introduction:
The appointment of primary school teachers in West Bengal and the legal validity of the recruitment process conducted by the West Bengal Board of Primary Education. The dispute arose from the filling up of 16,500 vacancies for primary school teachers based on specified qualifications and the Teacher Eligibility Test (TET) 2014.
Factual Matrix:
The West Bengal Board of Primary Education notified 16,500 vacancies for primary school teachers, with a qualification criterion including the TET-2014. Subsequent legal challenges led to directions from the Calcutta High Court regarding the filling of vacancies.
Submissions:
The parties presented arguments regarding the procedure specified in the Recruitment Rules, 2016, for selection of candidates, the validity of the Merit List, and the authority's discretion in making appointments.
Discussion:
The Supreme Court analyzed the procedure for candidate selection as per the Recruitment Rules, 2016, emphasizing the comprehensive evaluation criteria. It also considered precedents regarding the validity of select lists and the authority's discretion in making appointments.
Conclusion:
The Supreme Court concluded that the directions issued by the Division Bench of the High Court were inconsistent with the recruitment rules. It held that the Merit List had expired after one year, and no appointments could be made from it thereafter. Additionally, a fresh recruitment process had commenced, rendering further appointments impermissible from the previous cycle.
Disposition:
The Supreme Court set aside the High Court judgments and ruled against the candidates' claims for appointments from the previous recruitment process. All pending applications were disposed of accordingly.
Case Title: Ali Hossain Mandal & Ors. Vs. West Bengal Board of Primary Education & Ors.
Citation: 2024 LawText (SC) (5) 92
Case Number: [Civil Appeal No. 1873 of 2024] [Civil Appeal No. 1874 of 2024] [Civil Appeal Nos. 1875-1876 of 2024]
Date of Decision: 2024-05-09