Selective Cancellation Of Recruitment Without Strong Justification Violates Article 14: Manipur High Court

The Manipur High Court held that while Dhanamanjuri University cited alleged irregularities, including blank tabulation sheets for Physics and Botany, to justify cancellation of the earlier selection, such action could not warrant complete restart of the recruitment process.

The Court drew a distinction between the originally advertised posts and additional vacancies, permitting fresh interviews only for the latter while maintaining protection over the disputed selections.

It further emphasised that recruitment decisions by public authorities must be supported by cogent reasons, adhere to principles of fairness and consistency, and cannot arbitrarily unsettle a completed selection process without adequate legal justification.

Justice A. Guneshwar Sharma noted that: “In respect of Physics and Botany, the data/tabulation sheets were allegedly found blank and marks were not assigned against any of the candidates. The Syndicate, after detailed deliberations, unanimously resolved to conduct fresh interview of the candidates who were invited and came for the interview held earlier.”

Background:

DMU had issued an advertisement dated 19.12.2020 to fill 88 posts of Assistant Professors across 22 subjects. Interviews were completed in 2021, but results were delayed. Pursuant to a Court direction, the University declared results on 29.02.2024, selecting candidates (including the present petitioners) for various subjects, including Physics and Botany.

However, shortly thereafter, an Emergency Syndicate Meeting on 18.07.2024 declared this result “null and void” and issued a fresh notification, excluding Physics and Botany and proposing fresh interviews for these subjects.

The petitioners, who had been selected pursuant to the notification dated 29.02.2024, contended that their selection was validly made in accordance with the original recruitment process and could not be arbitrarily nullified. They argued that the subsequent cancellation of the results, without cogent reasons, was discriminatory and violative of Article 14 of the Constitution.

It was further submitted that the University could not alter the rules of the game after the selection process had been completed. According to the petitioners, even if fresh interviews were to be conducted, the same ought to be confined only to the additional vacancies and not to the posts for which candidates had already been duly selected.

The Court examined the University's decision to cancel the earlier selection only for Physics and Botany while retaining selections for other subjects, and stated that such selective action required strong justification.

The Court held that once a selection process has been completed and results declared, it cannot be annulled lightly. The University's reliance on alleged blank tabulation sheets was found to be a serious but disputed issue, requiring proper verification rather than outright cancellation.

The Court noted that the University cancelled the selection only for Physics and Botany while accepting results for all other subjects from the same process. This selective approach, the Court remarked, required strong and rational justification.

Case Name: Dr. Thongram Kamala Devi v/s The Dhanamanjuri University

Case No.: WP ( C) No. 633 of 2024 & Ors.

Date of Decision: 09.04.2026

Click Here To Read/Download Order