Court’s Decision:
The Calcutta High Court dismissed the writ petition challenging the selection process for the post of Assistant Headmaster at Raghunathbari Ramtarak High School (H.S.), rejecting claims of malafide intent, procedural irregularities, and violations in committee constitution. The court emphasized that without substantial proof of illegality or bias, judicial interference is unwarranted.
Facts:
The petitioner, an Assistant Teacher at the respondent school, applied for the Assistant Headmaster position but was not selected. She alleged irregularities in the selection process, particularly in the score sheet and panel prepared, asserting that the majority members’ scores indicated her as the leading candidate. The petitioner also challenged the selection committee’s composition, contending that certain members acted with bias and malafide intent.
Issues:
- Whether the selection process and committee constitution followed due process as per the established guidelines.
- Whether alleged malafide actions or biases influenced the selection process to warrant judicial intervention.
Petitioner’s Arguments:
The petitioner argued that:
- The selection committee’s composition deviated from established guidelines, specifically regarding the selection of the teacher’s representative.
- Certain committee members acted with malafide motives, awarding her disproportionately low scores without justification, despite her seniority and superior academic credentials.
- The irregularities justified annulling the selection process and creating a new panel based on cumulative scores from unbiased committee members.
Respondent’s Arguments:
The respondents, including the school authorities and the selected candidate, contended that:
- The selection process was conducted transparently and per prescribed guidelines.
- The petitioner’s challenge was an attempt by an unsuccessful candidate to disrupt a fair process.
- Judicial interference in expert committee decisions is limited unless proven malafides or irregularities are evident.
Analysis of the Law:
The court reviewed guidelines, particularly Memo No. 1628, outlining the selection process and committee constitution. It examined precedents emphasizing the judiciary’s limited role in expert committee matters unless significant legal or procedural violations are established.
Precedent Analysis:
The court referenced Supreme Court decisions:
- Ashok Kumar Yadav v. State of Haryana: Reinforced the need for fairness in viva-voce tests.
- Dalpat Abasaheb Solunke v. Dr. B.S. Mahajan: Stressed minimal judicial interference in expert committee matters absent illegality or malafide intent.
- Jadab Chandra Mukhopadhyay v. State of West Bengal: Allowed court intervention in cases of evident malafide or procedural lapses.
Court’s Reasoning:
The court found no substantial evidence of irregularities or malafide actions by the selection committee members. It noted that the petitioner’s participation in the meeting where the teacher’s representative was chosen barred her from later contesting the process. Additionally, the court held that judicial review does not extend to re-evaluating committee scores based on subjective dissatisfaction without concrete proof of bias.
Conclusion:
The court concluded that the selection process adhered to legal guidelines, and the petitioner’s claims of bias were unsubstantiated. Accordingly, the writ petition was dismissed.
Implications:
This judgment underscores the judiciary’s restrained approach in intervening in expert committee matters and reaffirms the need for substantive evidence of irregularity or malafide intent for court interference in administrative selections.
