The Supreme Court has dismissed a civil appeal filed by advocate Manoj Goyal challenging the Rajasthan High Court's recruitment process for Additional District Judges, holding that he could not seek appointment after participating in the selection process under the amended rules and failing to secure the prescribed minimum marks in the interview. The Court also affirmed the Rajasthan High Court's decision refusing to reopen a recruitment process that concluded more than a decade ago.
Background of the Case
The dispute arose from the recruitment process for Additional District Judges under the advocates' quota in Rajasthan. Initially, the Rajasthan Judicial Service Rules, 2010 did not prescribe minimum qualifying marks for the interview. However, before the fresh recruitment process began in 2011, Rule 41 was amended to require candidates to obtain at least 25% marks in the interview for appointment.
Manoj Goyal cleared the written examination and secured 161 out of 250 marks. After the interview, he obtained an aggregate score of 168 marks, which would have placed him 11th on overall merit. However, he received only 7 out of 30 marks in the interview, falling short of the minimum qualifying requirement of 7.5 marks by just 0.5 marks. As a result, he was not selected despite having a higher aggregate score than some successful candidates.
He challenged the validity of the amended Rule 41, arguing that it was contrary to the recommendations accepted by the Supreme Court in the All India Judges Association case and that vacancies originating before the amendment should have been governed by the earlier rules.
Court's Observations
The Bench of Justice Sanjay Karol and Justice Prasanna B. Varale rejected these submissions.
The Court held that the recommendations of the Shetty Commission regarding the absence of a viva voce cut-off were only guiding principles and did not override statutory recruitment rules framed by the competent authority.
Emphasising the importance of interviews for judicial appointments, the Bench observed:
"The 25% cut-off was a rational, considered benchmark prescribed to preserve the integrity and quality of judicial administration."
The Court further noted that the post of Additional District Judge requires qualities that cannot be assessed solely through written examinations, including alertness, judgment, dependability and decision-making ability.
The Bench also invoked the settled legal principle that a candidate who participates in a recruitment process with full knowledge of its rules cannot challenge those rules after being declared unsuccessful.
"The appellant, having participated in the written examination and interview process under the Amended Rules of 2011 with open eyes, without raising any protest cannot turn his back to challenge the rules of the game," the Court observed.
The Supreme Court also noted that the disputed interview cut-off had already been removed from the Rajasthan Judicial Service Rules in 2017. Moreover, the recruitment process had concluded in 2013, and the selected officers had been serving as Additional District Judges for over a decade.
According to the Bench, granting relief now would unsettle the seniority of serving judicial officers, affect the rights of appointed candidates, and potentially trigger similar claims from other unsuccessful candidates.
The Court observed that reopening such an old selection process would undermine certainty and finality in public appointments.
Decision
Dismissing the appeal, the Supreme Court upheld the Rajasthan High Court's judgment dated 8 February 2018. It ruled that the challenge to Rule 41 had become academic after the provision's deletion, that the interview cut-off was valid when the recruitment was conducted, and that the appellant had no enforceable right to appointment after failing to secure the prescribed interview marks. Pending applications were also disposed of, with no order as to costs.
Case Details:
Case Title: Manoj Goyal vs. Rajasthan High Court & Ors.
Case Number: Civil Appeal No. 8142 of 2018
Judge: Justice Sanjay Karol and Justice Prasanna B. Varale
Decision Date: 13 July 2026
