In a significant ruling on judicial service recruitment, the Supreme Court on Tuesday set aside a Madhya Pradesh High Court directive that had ordered a fresh “third” main examination for Civil Judge (Entry Level) candidates. The bench of Justices Pamidighantam Sri Narasimha and Atul S. Chandurkar held that the High Court exceeded its powers by reopening the matter through a review petition after having already dismissed similar pleas earlier.
Background
The dispute traces back to a 2023 advertisement to fill 199 Civil Judge vacancies in Madhya Pradesh. Rule 7 of the state’s Judicial Service Recruitment Rules was amended in June 2023, tightening eligibility-requiring three years’ continuous legal practice or high marks without any backlogs. Though the amendment faced challenges, the Supreme Court allowed all earlier-eligible candidates to sit for the preliminary exam pending a final verdict.
When results came in March 2024, two candidates, Jyotsna Dohalia and another, fell short of the 113-mark cut-off by a whisker. Their initial writ challenging the cut-off was dismissed on 7 May 2024, with the High Court noting they simply hadn’t met the minimum score.
Court’s Observations
Despite that dismissal, the same candidates sought a review. In June 2024, a Division Bench astonishingly ordered the recruitment board to drop ineligible candidates, recalculate the cut-off, and even conduct a fresh main exam. The Supreme Court took a dim view.
“The High Court proceeded on the premise that there was a likelihood of ineligible candidates securing appointment,” Justice Chandurkar observed, adding that the earlier judgment had already rejected such apprehensions.
The bench reminded that review powers exist only to correct clear errors, not to “re-argue what has already been decided.” Counsel for the Madhya Pradesh High Court argued that no ineligible candidate would ever reach the interview stage, an assurance backed by the Registrar’s affidavit. The Supreme Court agreed, stressing that mere fears of unfairness could not justify a new examination.
Decision
Setting aside the June 2024 review order, the apex court dismissed the review petition entirely and directed the High Court to finish the recruitment “at the earliest” based on the original process. “There was no occasion to invoke review jurisdiction and direct holding of a fresh main examination,” the bench ruled, effectively closing the door on another round of testing.
Case: High Court of Madhya Pradesh & Anr. vs. Jyotsna Dohalia & Anr.
Date of Judgment: 23 September 2025