NCVT certificate holders challenged the amended educational qualification prescribing a diploma in Sanitary Inspector for municipal recruitment. The High Court held prescription of qualifications is a matter of recruitment policy for the State, found no manifest arbitrariness, and declined to direct amendment of the rules.
This page shows the compact analysis of this judgement. The full analysis — procedural history, issue-by-issue holdings with ratio and obiter, advocates, and paragraph-level evidence for every claim — is being added to the record in batches and will appear here when this judgement has been through it.
Page 1 of 23
{W.P.(S)No.8150/2018}
2024:CGHC:47936-DB
Digitally 2024:CGHC:47936-DB signed by
SISTA AFR SISTA SOMAYAJULU SOMAYAJULU Date: 2024.12.06
15:58:53 HIGH COURT OF CHHATTISGARH AT BILASPUR +0530
WPS No. 8150 of 2018
Order reserved on: 20-11-2024
Order delivered on: 5-12-2024
Page 2 of 23
{W.P.(S)No.8150/2018}
... Petitioners
versus
| For Petitioners | : Mr. Prateek Sharma and Ms. Harleen Kaur, Advocates. |
|---|---|
| For Respondents No.1 to 3 | : Mr. Rahul Tamaskar, Govt. Advocate & Mr. Sharad |
| & 5 / State | Mishra, Panel Lawyer. |
| For Respondent No.4 | : Ms. Shreyadeep Gupta, Advocate. |
| For Respondent No.6 | : Mr. Abhyuday Singh, Advocate. |
Page 3 of 23
{W.P.(S)No.8150/2018}
Division Bench: -
Hon'ble Shri Sanjay K. Agrawal and Hon'ble Shri Radhakishan Agrawal, JJ.
CAV Order
Sanjay K. Agrawal, J.
Brief Facts
Page 4 of 23
{W.P.(S)No.8150/2018}
Sanitary Inspector examination was required for direct recruitment on the post of Sanitary Inspector, however, now, by way of the impugned amendment, rule has been amended and now, by the impugned amendment, the candidate has to pass B.Sc. in Biology from any recognised University and diploma in Sanitary Inspector from any recognised institute. It is the further case of the petitioners that they have passed National Trade Certificate course from the recognised NCVT, however, they have been excluded from consideration (who have obtained certificate course of National Trade Certificate from the NCVT), which is per se arbitrary, illegal and contrary to law and therefore rule to that extent deserves to be declared invalid and unconstitutional, as there is no legal nexus sought to be achieved by recognising diploma in Sanitary Inspector from recognised institute and as such, the subject rule enacted by way of the impugned amendment is not only arbitrary, but also suffers from vice of unreasonableness, therefore, it deserves to be struck down as unconstitutional to that extent by which the petitioners, who have passed National Trade Certificate conducted by the NCVT in the trade of Health Sanitary Inspector, have been excluded for consideration on the post of Sanitary Inspector in municipal services. The petitioners had also sought to challenge the notification dated 5th October, 2018 (Annexure P-3) by which the State Government has directed all the Commissioners of the
Page 5 of 23
{W.P.(S)No.8150/2018}
Municipal Corporations and all the Chief Municipal Officers of the Municipal Councils / Nagar Panchayats only to recruit the candidates those who have obtained B.Sc. in Biology from recognised University and have obtained diploma in Sanitary Inspector from recognised institute, on the post of Sanitary Inspector, considering the nature and challenges faced by the municipalities in sanitation and administration of local municipal bodies.
Submissions
Page 6 of 23
{W.P.(S)No.8150/2018}
consideration on the post Sanitary Inspector. He would further submit that work and duties required to be executed by the Sanitary Inspector are covered under the course of trade certificate issued by the NCVT, therefore, the petitioners are duly eligible for the post of Sanitatory Inspector on the basis of certificate issued by the NCVT and there is no difference between certificate course of the NCVT and diploma course of local institution, as both are one year courses and on the contrary, the certificate course is on better footing by having statutory colour and there is no complaint from the appointed Sanitary Inspectors working in various municipalities having NCVT certificate and they are discharging their duties efficiently. As such, the impugned rules to that extent be declared unconstitutional and the impugned notification Annexure P-3 deserves to be quashed. In support of his contention, Mr. Sharma, learned counsel, would rely upon the decisions of the Supreme Court in the matters of Sudhir Kumar Consul v. Allahabad Bank 1, Lok Prahari Through its General Secretary v. State of Uttar Pradesh and others 2, State of Punjab and another v. Brijeshwar Singh Chahal and another 3, K.S. Puttaswamy and another v. Union of India and others 4 and Kumari Shrilekha
Vidyarthi and others v. State of U.P. and others 5.
1 (2011) 3 SCC 486
2 (2018) 6 SCC 1
3 (2016) 6 SCC 1
4 (2017) 10 SCC 1
5 (1991) 1 SCC 212
Page 7 of 23
{W.P.(S)No.8150/2018}
the State / respondents No.1 to 3 and 5, would submit that decision of the State Government prescribing qualification for the post of Sanitary Inspector is a well considered policy decision of the State and that has been taken into account considering the challenges faced by the municipalities in the field of sanitation, which is purely the domain of the State Government and this Court would not like to interfere in the same, as the State as an employer has every right to seek better qualified candidates instead of lesser qualified candidates that too for the work of sanitation which is very much essential after the onslaught of COVID-19 during which period the municipalities had faced great challenges in keeping the municipal areas sanitized and therefore rules have been amended to seek diploma in Sanitary Inspector for the said post which is a considered effort to bring the qualification of the selected Sanitary Inspectors at par with the requirement of other States in India. Thus, the writ petition deserves to be dismissed having no merit.
: Principles for examining Constitutional Validity for Acts/Rules
Page 8 of 23
{W.P.(S)No.8150/2018}
transgressed other constitutional mandates, such as those relating to fundamental rights, is always on the person who challenges its vires . [See: Principles of Statutory Interpretation by Justice G.P. Singh, 12th Edition, page 592.]
6 (2017) 9 SCC 1
7 (1985) 1 SCC 641 : 1985 SCC (Tax) 121
Page 9 of 23
{W.P.(S)No.8150/2018}
Article 14. Manifest arbitrariness, therefore, must be something done by the legislature capriciously, irrationally and/or without adequate determining principle. Also, when something is done which is excessive and disproportionate, such legislation would be manifestly arbitrary. We are, therefore, of the view that arbitrariness in the sense of manifest arbitrariness as pointed out by us above would apply to negate legislation as well under Article 14. ”
and others 8, it has been held by a three-judge Bench of the Supreme Court that judicial review is a powerful weapon to restrain unconstitutional exercise of power by the legislature and executive by observing as under: -
“68. It could thus be seen that the role of the judiciary is to ensure that the aforesaid two organs of the State i.e. the Legislature and Executive function within the constitutional limits. Judicial review is a powerful weapon to restrain unconstitutional exercise of power by the legislature and executive. The role of this Court is limited to examine as to whether the Legislature or the Executive has acted within the powers and functions assigned under the Constitution. However, while doing so, the court must remain within its self-imposed limits. ”
earlier decisions, speaking through B.R. Gavai, J., have held that the statute enacted by the Parliament or a State Legislature cannot be declared unconstitutional lightly, and observed as under :-
9 (2017) 7 SCC 59
8 2023 SCC OnLine SC 813
Page 10 of 23
{W.P.(S)No.8150/2018}
“70. It could thus be seen that this Court has held that the statute enacted by Parliament or a State Legislature cannot be declared unconstitutional lightly. To do so, the Court must be able to hold beyond any iota of doubt that the violation of the constitutional provisions was so glaring that the legislative provision under challenge cannot stand. It has been held that unless there is flagrant violation of the constitutional provisions, the law made by Parliament or a State Legislature cannot be declared bad.
71. It has been the consistent view of this Court that legislative enactment can be struck down only on two grounds. Firstly, that the appropriate legislature does not have the competence to make the law; and secondly, that it takes away or abridges any of the fundamental rights enumerated in Part III of the Constitution or any other constitutional provisions. It has been held that no enactment can be struck down by just saying that it is arbitrary or unreasonable. Some or the other constitutional infirmity has to be found before invalidating an Act. It has been held that Parliament and the legislatures, composed as they are of the representatives of the people, are supposed to know and be aware of the needs of the people and what is good and bad for them. The court cannot sit in judgment over their wisdom.
72. It has been held by this Court that there is one and only one ground for declaring an Act of the legislature or a provision in the Act to be invalid, and that is if it clearly violates some provision of the Constitution in so evident a manner as to leave no manner of doubt. It has further been held that if two views are possible, one making the statute constitutional and the other making it unconstitutional, the former view must always be preferred. It has been held that the Court must make every effort to uphold the constitutional validity of a statute, even if that requires giving a strained construction or narrowing down its scope.
73. It has consistently been held that there is always a presumption in favour of constitutionality, and a law will not be declared unconstitutional unless the case is so clear as to be free from doubt. It has been held that if the law which is passed is within the scope of the power conferred on a
Page 11 of 23
{W.P.(S)No.8150/2018}
legislature and violates no restrictions on that power, the law must be upheld whatever a court may think of it.
74. It could thus be seen that the challenge to the legislative Act would be sustainable only if it is established that the legislature concerned had no legislative competence to enact on the subject it has enacted. The other ground on which the validity can be challenged is that such an enactment is in contravention of any of the fundamental rights stipulated in Part III of the Constitution or any other provision of the Constitution. Another ground as could be culled out from the recent judgments of this Court is that the validity of the legislative act can be challenged on the ground of manifest arbitrariness. However, while doing so, it will have to be remembered that the presumption is in favour of the constitutionality of a legislative enactment. ”
Shikshan Samiti and another 10, their Lordships of the Supreme Court have held that there is always a presumption in favour of constitutionality or validity of a subordinate legislation and the burden is upon him who attacks it to show that it is invalid. B.R. Gavai, J., speaking for the Supreme Court, held in paragraphs 27 & 28 of the report as under: -
“27. It could thus be seen that this Court has held that the subordinate legislation may be questioned on any of the grounds on which plenary legislation is questioned. In addition, it may also be questioned on the ground that it does not conform to the statute under which it is made. It may further be questioned on the ground that it is contrary to some other statute. Though it may also be questioned on the ground of unreasonableness, such unreasonableness should not be in the sense of not being reasonable, but should be in the sense that it is manifestly arbitrary.
10 (2022) 6 SCC 65
Page 12 of 23
{W.P.(S)No.8150/2018}
28. It has further been held by this Court in the said case that for challenging the subordinate legislation on the ground of arbitrariness, it can only be done when it is found that it is not in conformity with the statute or that it offends Article 14 of the Constitution. It has further been held that it cannot be done merely on the ground that it is not reasonable or that it has not taken into account relevant circumstances which the Court considers relevant. ”
v. Union of 13.Similarly, in the matter of PGF Limited and others
India and another 11, their Lordships of the Supreme Court have laid down certain guidelines by taking note of certain precautions to be observed whenever the vires of any provision of law is raised before the Court and cautioned the Courts in paragraph 37 as under:-
“37. The Court can, in the first instance, examine whether there is a prima facie strong ground made out in order to examine the vires of the provisions raised in the writ petition. The Court can also note whether such challenge is made at the earliest point of time when the statute came to be introduced or any provision was brought into the statute book or any long time-gap exists as between the date of the enactment and the date when the challenge is made. It should also be noted as to whether the grounds of challenge based on the facts pleaded and the implication of the provision really has any nexus apart from the grounds of challenge made. With reference to those relevant provisions, the Court should be conscious of the position as to the extent of public interest involved when the provision operates the field as against the prevention of such operation. The Court should also examine the extent of financial implications by virtue of the operation of the provision vis-a-vis the State and alleged extent of sufferance by the person who seeks to challenge based on the alleged invalidity of the provision with particular reference to the vires made. Even if the writ court is of the
11 (2015) 13 SCC 50
Page 13 of 23
{W.P.(S)No.8150/2018}
view that the challenge raised requires to be considered, then again it will have to be examined, while entertaining the challenge raised for consideration, whether it calls for prevention of the operation of the provision in the larger interest of the public. We have only attempted to set out some of the basic considerations to be borne in mind by the writ court and the same is not exhaustive. In other words, the writ court should examine such other grounds on the above lines for consideration while considering a challenge on the ground of vires to a statute or the provision of law made before it for the purpose of entertaining the same as well as for granting any interim relief during the pendency of such writ petitions. For the above-stated reasons it is also imperative that when such writ petitions are entertained, the same should be disposed of as expeditiously as possible and on a time-bound basis, so that the legal position is settled one way or the other. ”
Unamended and Amended Provisions
under: -
vuqlwph 3
¼nsf[k;s fu;e 6½
¼uxjikfydk deZpkfj;ksa dsinuke]osrueku ,oa ‘kS{kf.kd vgZrk lEcU/kh lkfj.kh½
| dzeakd ¼1½ |
Iknuke ¼2½ |
osrueku oxhZdj.k ds vuqlkj ¼3½ |
‘kS{kf.k |
d vgZrk ¼4½ |
|---|---|---|---|---|
| 5- | LoPNrk fujh{kd | :120&120&4&140 &5&160&n-jks- &6&190 |
lh/khZ HkrhZ ds fy, ekU;rk izkIr laLFkk dh ijh{kk mrh.kZ foHkkxh; inksUufr ijh{kk gksus dk ize dk;Zdze esa de iwokZuqHkoA mEehn tkuk gksxk vkSj ekU;rk izkIr laLFkk dh ijh{kk mrh.kZ izkIr djuk gksxkA |
Nrhlx<+ ‘kklu }kjk dh LoPNrk fujh{kd gksus dk izek.k i=A ds fy, ek/;fed k.k&i= ,oa LoPNrk ls de 3 o”kZ dk okj dks izf’k{k.k esa Nrhlx<+’kklu }kjk ls LoPNrk fujh{kd gksus dk izek.k i= |
Page 14 of 23
{W.P.(S)No.8150/2018}
under:-
| (1) | (2) | (3) | (4) |
|---|---|---|---|
| 5. | Sanitary | Rs.5200- | Should have passed B.Sc. in Biology from any |
| Inspector | 20200+Grade | recognised University and diploma in Sanitary | |
| pay2800 | Inspector from anyrecognised institute. |
Judicial Precedents
Page 15 of 23
{W.P.(S)No.8150/2018}
as a condition of eligibility. In the matter of Puneet Sharma and others v. J.P. Chaurasia and another 12 , their Lordships of the Supreme Court relying upon their earlier judgments in the matters of P.M. Latha v. State of Kerala 13 v. Kerala Public , Jyoti K.K. Service Commission 14 and State of Punjab v. Anita 15 have observed in paragraph 29 as under:-
“29. Thereafter, the Court discussed the previous rulings in P.M. Latha13 , Jyoti K.K.14 and Anita15 , then concluded that the candidature of the diploma holders was correctly rejected and held as follows: Zahoor Ahmad Rather case16 , SCC pp. 414-15, paras 26-27)
“26. We are in respectful agreement with the interpretation which has been placed on the judgment in Jyoti K.K.14 in the subsequent decision in Anita15 . The decision in Jyoti K.K.14 turned on the provisions of Rule 10( a )( ii ). Absent such a rule, it would not be permissible to draw an inference that a higher qualification necessarily presupposes the acquisition of another, albeit lower, qualification. The prescription of qualifications for a post is a matter of recruitment policy. The State as the employer is entitled to prescribe the qualifications as a condition of eligibility. It is no part of the role or function of judicial review to expand upon the ambit of the prescribed qualifications. Similarly, equivalence of a qualification is not a matter which can be determined in exercise of the power of judicial review. Whether a particular qualification should or should not be regarded as equivalent is a matter for the State, as the recruiting authority, to determine. The decision in Jyoti K.K.14 turned on a specific statutory rule under which the holding of a higher
12 (2021) 16 SCC 340
13 (2003) 3 SCC 541
14 (2010) 15 SCC 596
15 (2015) 2 SCC 170
16 Zahoor Ahmad Rather v. Imtiyaz Ahmad, (2019) 2 SCC 404
Page 16 of 23
{W.P.(S)No.8150/2018}
qualification could presuppose the acquisition of a lower qualification. The absence of such a rule in the present case makes a crucial difference to the ultimate outcome. In this view of the matter, the Division Bench17 of the High Court was justified in reversing the judgment18 of the learned Single Judge and in coming to the conclusion that the appellants did not meet the prescribed qualifications. We find no error in the decision17 of the Division Bench.
27. While prescribing the qualifications for a post, the State, as employer, may legitimately bear in mind several features including the nature of the job, the aptitudes requisite for the efficient discharge of duties, the functionality of a qualification and the content of the course of studies which leads up to the acquisition of a qualification. The State is entrusted with the authority to assess the needs of its public services. Exigencies of administration, it is trite law, fall within the domain of administrative decisionmaking. The State as a public employer may well take into account social perspectives that require the creation of job opportunities across the societal structure. All these are essentially matters of policy. Judicial review must tread warily. That is why the decision in Jyoti K.K.14 must be understood in the context of a specific statutory rule under which the holding of a higher qualification which presupposes the acquisition of a lower qualification was considered to be sufficient for the post. It was in the context of specific rule that the decision in Jyoti K.K.14 turned. ””
17 Imtiyaz Ahmad v. Zahoor Ahmad Rather, LPA (SW) No.135 of 2017, decided on 12-102017 (J&K).
18 Zahoor Ahmad Rather v. State of J&K, 2017 SCC OnLine J&K 936.
Page 17 of 23
{W.P.(S)No.8150/2018}
not be accepted as equivalent to the qualification prescribed by the
authority (see State of Rajasthan and others v. Lata Arun 19).
19 (2002) 6 SCC 252
Page 18 of 23
{W.P.(S)No.8150/2018}
such, considering the exigencies of service and considering the need of the municipalities in the broader public interest, the State Government has taken a decision that the candidates intending to aspire for appointment on the post of Sanitary Inspector must have diploma in Sanitary Inspector from a recognised institute, which is absolutely well considered policy decision of the Government to offer the post of Sanitary Inspector holding that those candidates who are having apart from Science graduation in Biology subject must have diploma in Sanitary Inspector which cannot be said to be suffering from vice of manifest arbitrariness or unreasonableness especially in light of the well considered parameters laid down by their Lordships of the Supreme Court lastly in Dental Council of India (supra).
Page 19 of 23
{W.P.(S)No.8150/2018}
certificate course of Health Sanitary Inspector conducted by the NCVT as a recognised course for appointment on the post of Sanitary Inspector?
under:-
25.The same principle was followed in the matter of Asif Hameed v.
State of J.K. 23 where the Supreme Court observed that:
“19. … The Constitution does not permit the court to direct or advise the executive in matter of policy or to sermonise qua any matter which under the Constitution lies within the sphere of the legislature or executive. …”
26.In the matter of Union of India v. Assn. for Democratic
Reforms 24, the Supreme Court observed that:
20 (1990) 2 SCC 707
21 1993 Supp (3) SCC 9
22 (1985) 3 SCC 169
23 1989 Supp (2) SCC 364
24 (2002) 5 SCC 294
Page 20 of 23
{W.P.(S)No.8150/2018}
“19. … it is not possible for this Court to give any directions for amending the Act or the statutory Rules. It is for Parliament to amend the Act and the Rules.”
Assn. v. Union of India 25, the Supreme Court held that a court cannot direct the legislature to enact a particular law. This is because under the constitutional scheme, Parliament exercises a sovereign power to enact law and no other authority can issue directions to frame a particular piece of legislation. This principle was reiterated in the matter of State of J&K v. A.R. Zakki 26, where this Court observed that:-
“10. … A writ of mandamus cannot be issued to the legislature to enact a particular legislation. Same is true as regards the executive when it exercises the power to make rules, which are in the nature of subordinate legislation. Section 110 of the J&K Constitution, which is on the same lines as Article 234 of the Constitution of India, vests in the Governor, the power to make rules for appointments of persons other than the District Judges to the Judicial Service of the State of J&K and for framing of such rules, the Governor is required to consult the Commission and the High Court. This power to frame rules is legislative in nature. A writ of mandamus cannot, therefore, be issued directing the State Government to make the rules in accordance with the proposal made by the High Court.”
Court referred to a large number of decisions and held that:-
“ 18 . Thus, it is crystal clear that the court has a very limited role and in exercise of that, it is not open to have
25 (1989) 4 SCC 187
26 1992 Supp (1) SCC 548
27 (2012) 2 SCC 542
Page 21 of 23
{W.P.(S)No.8150/2018}
judicial legislation. Neither the court can legislate, nor has it any competence to issue directions to the legislature to enact the law in a particular manner.”
“ 127 . The law having been laid down by a larger Bench than in Gainda Ram it is quite clear that the decision, whether or not Section 8 of the Representation of the People Act, 1951 is to be amended, rests solely with Parliament.”
30.In the matter of State of Himachal Pradesh and others v. Satpal
Saini 29, the Supreme Court delineating the powers of executive, legislature and judiciary, has held as under:-
28 (2014) 9 SCC 1 29 (2017) 11 SCC 42
Page 22 of 23
{W.P.(S)No.8150/2018}
or the legislature to convert it into enacted law. It is wise to remind us of these limits and wiser still to enforce them without exception.”
31.Likewise, in the matter of Ms. Eera, through Dr. Manjula
Krippendorf v. State (Govt. of NCT of Delhi) and another 30, the
Supreme Court has held as under:-
“124. … In short, the difference is the well-known philosophical difference between “is” and “ought”. Does the Judge put himself in the place of the legislator and ask himself whether the legislator intended a certain result, or does he state that this must have been the intent of the legislator and infuse what he thinks should have been done had he been the legislator. If the latter, it is clear that the Judge then would add something more than what there is in the statute by way of a supposed intention of the legislator and would go beyond creative interpretation of legislation to legislating itself. It is at this point that the Judge crosses the Lakshaman Rekha and becomes a legislator, stating what the law ought to be instead of what the law is.”
Analysis
30 (2017) 15 SCC 133
Page 23 of 23
{W.P.(S)No.8150/2018}
Sanitary Inspector conducted by the NCVT is the recognised qualification for the post of Sanitary Inspector, as directing the State either to treat the same as equivalent course for Sanitary Inspector or to amend the schedule to the Rules of 1967 would amount to crossing the laxman rekha , which is totally prohibited for the courts.
(supra), Lok Prahari (supra), Brijeshwar Singh Chahal’s (supra), K.S. Puttaswamy (supra) and Kumari Shrilekha Vidyarthi (supra) are not applicable to the present case and distinguishable on facts.
Conclusion
Sd/Sd/(Sanjay K. Agrawal) (Radhakishan Agrawal) JUDGE JUDGE
Soma
2 issues framed by the court
Is the amended qualification for Sanitary Inspector (B.Sc. Biology plus diploma from a recognised institute), excluding NCVT National Trade Certificate holders, manifestly arbitrary?
Can a writ be issued directing the rule-making authority to recognise the NCVT certificate course as a qualification for the post?
Colour shows how this judgement treated each authority
Sudhir Kumar Consul v. Allahabad BankDistinguished¶33
(2011) 3 SCC 486 · Who else cites this
Lok Prahari Through its General Secretary v. State of Uttar PradeshDistinguished¶33
(2018) 6 SCC 1 · Who else cites this
State of Punjab v. Brijeshwar Singh ChahalDistinguished¶33
(2016) 6 SCC 1 · Who else cites this
K.S. Puttaswamy v. Union of IndiaDistinguished¶33
(2017) 10 SCC 1 · Who else cites this
Kumari Shrilekha Vidyarthi v. State of U.P.Distinguished¶33
(1991) 1 SCC 212 · Who else cites this
Shayara Bano v. Union of IndiaRelied on¶9
(2017) 9 SCC 1 · Who else cites this
Dr. Jaya Thakur v. Union of IndiaRelied on¶10
2023 SCC OnLine SC 813 · Who else cites this
Binoy Viswam v. Union of IndiaReferred¶11
(2017) 7 SCC 59 · Who else cites this
Dental Council of India v. Biyani Shikshan SamitiRelied on¶12
(2022) 6 SCC 65 · Who else cites this
PGF Limited v. Union of IndiaRelied on¶13
(2015) 13 SCC 50 · Who else cites this
Puneet Sharma v. J.P. ChaurasiaRelied on¶17
(2021) 16 SCC 340 · Who else cites this
P.M. Latha v. State of KeralaReferred¶17
(2003) 3 SCC 541 · Who else cites this
Jyoti K.K. v. Kerala Public Service CommissionReferred¶17
(2010) 15 SCC 596 · Who else cites this
State of Punjab v. AnitaReferred¶17
(2015) 2 SCC 170 · Who else cites this
Zahoor Ahmad Rather v. Imtiyaz AhmadRelied on¶19
(2019) 2 SCC 404 · Who else cites this
State of Rajasthan v. Lata ArunReferred¶18
(2002) 6 SCC 252 · Who else cites this
Mallikarjuna Rao v. State of A.P.Relied on¶23
(1990) 2 SCC 707 · Who else cites this
V.K. Sood v. Deptt. of Civil AviationRelied on¶23
1993 Supp (3) SCC 9 · Who else cites this
State of H.P. v. Parent of a Student of Medical CollegeRelied on¶24
(1985) 3 SCC 169 · Who else cites this
Asif Hameed v. State of J&KRelied on¶25
1989 Supp (2) SCC 364 · Who else cites this
Union of India v. Assn. for Democratic ReformsRelied on¶26
(2002) 5 SCC 294 · Who else cites this
Supreme Court Employees' Welfare Assn. v. Union of IndiaRelied on¶27
(1989) 4 SCC 187 · Who else cites this
State of J&K v. A.R. ZakkiRelied on¶27
1992 Supp (1) SCC 548 · Who else cites this
V.K. Naswa v. Union of IndiaRelied on¶28
(2012) 2 SCC 542 · Who else cites this
Manoj Narula v. Union of IndiaRelied on¶29
(2014) 9 SCC 1 · Who else cites this
3 provisions across 2 enactments
Uttara Kumar Mahilange and 10 others (petitioners holding NCVT National Trade Certificate in Health Sanitary Inspector trade)
State of Chhattisgarh through the Secretary, Urban Administration and Development Department
The Director, Urban Administration and Development Department
The Under Secretary, Urban Administration and Development Department
The Chhattisgarh Professional Examination Board through the Secretary
All India Institute of Local Self Government
Sanjay K. Agrawal
Radhakishan Agrawal
As recorded by the court registry
Judgements on the same questions, provisions and authorities, from every court
