The Madhya Pradesh High Court has reaffirmed that substantial alterations to recruitment quotas in government services cannot be made arbitrarily, especially when they undermine long-standing promotional rights of existing employees. The judgment underscores that constitutional guarantees of equality and non-arbitrariness bind administrative decisions in public employment.
Background & Facts
The Dispute
The petitioners, serving employees eligible for promotion to the post of "Sister Tutor" in the state health services, challenged a government notification dated 21.03.2024 that revised the recruitment ratio for the position. Previously, the ratio was 10% direct recruitment and 90% promotion. The amended notification reversed this to 90% direct recruitment and 10% promotion, effectively reducing promotional avenues for incumbent staff who had served for years under the expectation of upward mobility.
Procedural History
- Prior Practice: For over a decade, the 10:90 ratio was consistently applied in recruitment for Sister Tutor posts.
- 2024 Notification: The State issued a new notification altering the ratio to 90:10 without any stated rationale or impact assessment.
- 2025 Advertisement: A recruitment drive was launched under the new ratio, triggering immediate challenges.
- Jabalpur Bench Order: In a parallel case (Renu Singh v. State of Madhya Pradesh, WP No. 50409 of 2025), the Single Bench at Jabalpur had issued an interim order staying recruitment pending final adjudication.
Relief Sought
The petitioners sought quashing of the 2024 notification and the 2025 advertisement, arguing that the revised ratio was arbitrary, violative of Article 14, and breached legitimate expectations formed over years of consistent policy.
The Legal Issue
The central question was whether a drastic reversal in the direct recruitment to promotion ratio - from 10:90 to 90:10 - constitutes arbitrary classification under Article 14 of the Constitution, particularly when it undermines the legitimate expectations of service personnel who relied on established promotional norms.
Arguments Presented
For the Petitioner
Counsel for the petitioners contended that the sudden shift violated the principle of reasonable classification under Article 14. He cited State of West Bengal v. Anwar Ali Sarkar and E.P. Royappa v. State of Tamil Nadu to argue that the change lacked intelligible differentia and rational nexus with any legitimate state objective. He emphasized that employees had built careers under the assumption of a 90% promotion quota, and altering it retroactively breached the doctrine of legitimate expectation.
For the Respondent
The State, through the Deputy Advocate General, argued that the amendment was a policy decision aimed at improving service quality by attracting qualified external candidates. He asserted that the State had unfettered discretion in framing recruitment rules under Article 309 and that the change did not violate any statutory provision. He further claimed that the petitioners had no vested right to promotion and that the new ratio was merely an administrative adjustment.
The Court's Analysis
The Court examined whether the alteration in recruitment ratio satisfied the twin requirements of Article 14: intelligible differentia and rational nexus. It held that the State failed to demonstrate any objective basis for the 90:10 shift. The Court noted that the previous 10:90 ratio had been in place for over a decade, and no performance or efficiency data was presented to justify such a radical reversal.
"The State cannot, without any material or rationale, upend a long-standing recruitment policy that employees have relied upon for career planning. Such a change, if not grounded in objective criteria, amounts to arbitrariness."
The Court distinguished State of U.P. v. Subhash Chandra where policy changes were upheld due to demonstrable administrative necessity. Here, no such necessity was shown. The Court also affirmed that legitimate expectation, though not a vested right, must be respected when the State has created a settled pattern of conduct. The abrupt reversal, without consultation or transitional safeguards, was found to be procedurally unfair and substantively unreasonable.
The Verdict
The petitioners succeeded. The Court held that the 2024 notification altering the recruitment ratio to 90% direct recruitment and 10% promotion was arbitrary and violative of Article 14. The advertisement dated 24.12.2025 was set aside, and recruitment under it was stayed pending final adjudication. The Court directed the State to reconsider the ratio with proper justification and public consultation.
What This Means For Similar Cases
Promotional Expectations Are Legally Recognized
- Practitioners must now argue that long-standing recruitment patterns create enforceable legitimate expectations, even absent statutory guarantee.
- Any policy shift must be accompanied by objective data, impact analysis, and a reasonable transition period.
Arbitrary Policy Changes Are Void Under Article 14
- Government departments cannot alter recruitment quotas based on whim or administrative convenience.
- Courts will scrutinize the nexus between the change and stated objectives - mere assertion of "policy discretion" is insufficient.
Interim Relief in Parallel Matters Must Be Harmonized
- When similar petitions are pending before different benches, courts must coordinate to avoid conflicting interim orders.
- Practitioners should cite parallel proceedings to strengthen applications for stay or consolidation.
