The Supreme Court has held that legal procedure must remain “a handmaiden of justice” and cannot be used as a punitive tool to perpetuate injustice. It directed the Jharkhand Public Service Commission (JPSC) to conduct the medical examination of a Scheduled Tribe candidate who had cleared the written stages of the state civil services exam but missed the medical test due to confusion over dates.
A bench of Justices Vikram Nath and Sandeep Mehta, while hearing the matter on September 4, emphasised that the candidate should not be punished disproportionately for a genuine mistake. The court observed:
“This court time and again has held that procedure is handmaiden of justice and it must not be made a tool to perpetuate injustice by employing oppressive or punitive measures.”
The candidate had qualified both the preliminary and mains rounds of the Jharkhand Combined Civil Services Competitive Examination, 2021, held in January 2022. As per JPSC’s advertisement, record verification was scheduled between May 8–15, 2022, followed by interviews from May 9–16. It further mentioned that medical tests of interviewees would be conducted “the next day” in a Ranchi hospital.
Believing that her test would fall on May 17 after the last date of interviews, the candidate appeared at the hospital on that date, only to be informed that her candidature had already been rejected for being absent the previous day.
Her plea before the Jharkhand High Court was dismissed in September 2024 on the ground that the selection process had concluded.
The top court criticised JPSC’s stance, noting that the wording of the advertisement itself gave rise to genuine doubt. It also faulted the absence of any mention of consequences for non-appearance, intentional or otherwise, and the lack of provision for a hearing in case of exigency.
The bench underlined the role of the State as a “model employer,” expected to act fairly and in line with constitutional equality principles. It said:
“To uphold the constitutional promise by uplifting individuals belonging to marginalised community such procedural hurdles must not be resorted to cause further hardship and injustice. The goal is upliftment and not finding out ways to reject them at the very threshold.”
The court further clarified that medical examinations are meant only to assess physical fitness and not merit.
Taking a lenient view, the Supreme Court granted the candidate a one-time relaxation. It directed JPSC to conduct her medical test and, if she clears it as per the applicable rules, to create a supernumerary post for her appointment.
The bench added that she would be entitled to continuity of service from the date the last selected candidate of the 2021 examination joined.
