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Sarita Kumari Vs the State of Jharkhand — Jharkhand HC (2026) — LawSathi Research

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Jharkhand HC
2026
Sarita Kumari Vs the State of JharkhandSarita Kumari v. the State of Jharkhand

Dismissed¶46

Sarita Kumari v. the State of Jharkhand

Jharkhand HC7 Jan 2026WPC/7739/2025

Case brief

AI extract

What is this about?

Keywords: Class-IV recruitment; Peon posts; Palamau district; Advertisement No.01/2025; Advertisement No.01/2010; minimum educational qualification; Matriculation; relaxation of qualification; non-matriculate; Class-8; Pay Band-1 (P.B-1); pay scale 5200-20200; Grade Pay 1800; Finance Department Resolution No.1859 dated 02.09.2011; Clause-5(क); Civil Appeal Nos. 13950-13951 of 2024; Supreme Court quashed 2010 appointments; Articles 14 and 16 of the Constitution; writ petition dismissed. Relevant to research on eligibility/educational-qualification criteria in Jharkhand Class-IV recruitment and challenges to qualification clauses in fresh advertisements issued after quashed recruitments.

What did the court decide?

For the Class-IV pay scale of 5200-20200 with Grade Pay 1800 (P.B-1), the minimum educational qualification of Matriculation fixed in the fresh Advertisement No.01/2025 accords with Clause-5(क) of the Finance Department Resolution No.1859 dated 02.09.2011.

What the court decided

AI extract

Outcome

Dismissed

Issue for consideration

Whether the petitioners, being non-matriculates qualified up to Class-8, are entitled to relaxation of the minimum educational qualification of Matriculation prescribed in fresh Advertisement No.01/2025 for Class-IV posts in the District of Palamau, so as to be allowed to apply for appointment.

Court's answer

For the Class-IV pay scale of 5200-20200 with Grade Pay 1800 (P.B-1), the minimum educational qualification of Matriculation fixed in the fresh Advertisement No.01/2025 accords with Clause-5(क) of the Finance Department Resolution No.1859 dated 02.09.2011.

Ratio / Principle

There is no illegality in the respondents fixing the minimum educational qualification as Matriculate; consequently no relief can be granted to the petitioners and the writ petition stands dismissed.

Detailed headnote1 paragraphs

W.P.(S) No. 7739 of 2025 (High Court of Jharkhand at Ranchi, Ananda Sen, J., decided 07.01.2026) — Thirteen applicants for Class-IV posts in the District of Palamau, whose qualification is up to Class-8 (non-matriculates), sought a direction to relax the minimum educational qualification of Matriculation prescribed in fresh Advertisement No.01/2025 (Pay Band-1, pay scale 5200-20200, Grade Pay 1800), published pursuant to the Supreme Court's order in Civil Appeal Nos. 13950-13951 of 2024, by which the 2010 Palamau advertisement (No.01/2010) and all appointments made under it were quashed as violative of Articles 14 and 16 of the Constitution. The Court held that, per Clause-5(क) of the Finance Department Resolution No.1859 dated 02.09.2011, Matriculation is the prescribed minimum qualification for that pay scale, found no illegality in the respondents' fixation of the qualification, granted no relief, and dismissed the writ petition.

A

2026:JHHC:248

IN THE HIGH COURT OF JHARKHAND AT RANCHI W.P.(S) No. 7739 of 2025

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Sarita Kumari aged about 43 years Daughter of Balram Ram, resident of village Baralota, P.O. G.L.A. College, P.S. Medininagar, District Palamau, Jharkhand.

Anand Kumar, aged about 37 years, son of Balram Ram, resident of village Baralota, P.O. G.L.A. College, P.S. Medininagar, District Palamau, Jharkhand.

Md. Khalik aged about 50 years son of Late Abdul Aziz resident of village Kerki, P.O. Panki, P.S. Panki, District Palamau, Jharkhand

Surendra Kumar, aged about 39 years, son of Balram Ram, resident of village Baralota, P.O. G.L.A. College, P.S. Medininagar, District Palamau, Jharkhand.

Manesh Oraon aged about 53 years son of Ramlagan Oraon resident of village AhirGurha, P.O. & P.S. Panki, District Palamau, Jharkhand.

Ramyad Oraon aged about 37 years son of Visu Oraon resident of village Mahugain, P.O. Panki Kala, P.S. Panki, District Palamau, Jharkhand.

Naimuddin Ansari, aged about 47 years, son of Late Rahmatullah Ansari, resident of village Loinga, P.O. Loinga, P.S. Patana, District Palamau, Jharkhand.

Kundal Prasad Gupta aged about 44 years son of Late Shiv Saw resident of Village PalheKalan, P.O. Palhekalan, P.S. Patan, District Palamau, Jharkhand.

Pawan Kumar aged about 40 years son of Kuldip Ram resident of village Sutha, P.O. Pandeypur, P.S. Patan, District Palamau, Jharkhand.

Md. Isaullah Roy, aged about 42, son of Md. Sahabuddin Roy, resident of Sutha village, P.O. Pandeypur, P.S. Patan, District Palamau, Jharkhand.

Bikesh Paswan aged about 35 years son of Bachhan Paswan resident of village Barkinemi, P.O. Jhakar, P.S. Medininagar, District Palamau, Jharkhand.

Rajesh Kumar aged about 39 years son of Chandradeo Paswan resident of village Belodar, P.O. Purhath Kataiya, P.S. Hariharganj, District Palamau, Jharkhand.

Sanjay Kumar aged about 54 years son of Ramraj Manjhi resident of village Kajri, P.O. Naudiha, P.S. Patan, District Palamau, Jharkhand. … … Petitioner(s)

Versus

The State of Jharkhand.

The Secretary, Department of Personnel Administrative Reforms and Rajbhasha, Govt. of Jharkhand, Project Building, P.O. Dhurwa, P.S. Jagarnathpur, District Ranchi, Jharkhand.

The Commissioner, Palamau Division, P.O. and P.S. Medininagar, District Palamau, Jharkhand.

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2026:JHHC:248

The Deputy Commissioner, Palamau P.O. and P.S. Medininagar, District Palamau, Jharkhand.

The Deputy Collector (Establishment), Palamau, P.O. and P.S. Medininagar, District Palamau, Jharkhand.

… … Respondent(s)

CORAM : SRI ANANDA SEN, J.

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For the Petitioner(s) : Mr. Dilip Kr. Prasad, Advocate For the Respondent(s) : Mr. Ravi Kerketta, SC-VI

Ms. Deepika Jojowar, AC to SC-VI Ms. Rituraj, AC to SC-VI

02/ 07^th January, 2026

1. Heard the parties.

2. By filing this writ petition, the petitioners pray for a direction upon the respondents to accept their applications pursuant to an Advertisement No.1/2025 published to appoint persons in Class-IV in the District of Palamau, after giving relaxation in the educational qualification.

3. The learned counsel appearing on behalf of the petitioners submits that the petitioners earlier applied pursuant to the Advertisement No.1/2010 which was published for the District of Palamau to fill-up the post of Peon i.e., a Class-IV posts. The said advertisement and the process thereafter, were challenged and ultimately the Hon’ble Supreme Court in Civil Appeal No.(s) 13950-13951 of 2024 had quashed the Advertisement including the consequence arising out of the said advertisement i.e., the appointments. A fresh advertisement was published to fill-up the posts but the petitioners being aggrieved by the minimum educational qualification clause has approached this Court.

The learned counsel for the petitioners further submits that now a fresh advertisement has been published wherein the minimum qualification has been prescribed as Matriculation. It is the grievance of the petitioners that the petitioners are nonmatriculates and their qualification is up to Class-8, thus, their educational qualification should be relaxed and they should be allowed to participate in the process of appointment.

2

2026:JHHC:248

4. Learned counsel appearing on behalf of the State submits that the Advertisement was published as per the Rules of appointment in the State of Jharkhand.

Further, he submits that the Advertisement has been published to fill-up the post in P.B-1 i.e., the Scale of 5200-20200 in Grade Pay of 1800 for which as per the Circular of the Finance Department, Matriculation is the minimum qualification.

5. After hearing the parties, I find that in 29^th July, 2010, the District of Palamau published an Advertisement to fill-up the Class-IV posts of Peon etc. The said Advertisement was numbered as 01/2010. Pursuant to the said advertisement, the petitioners applied, though they were not selected. The said Advertisement 01/2010 of Palamau District was the subject matter of the Civil Appeal No.(s) 13950-13951 of 2024 as challenge was thrown to the said Advertisement on the ground of illegality/irregularity. The Hon’ble Supreme Court after hearing the parties, set aside the aforesaid Advertisement, as the said Advertisement was in violation of Article 14 and 16 of the Constitution of India and other judicial precedents of the Hon’ble Supreme Court. The Hon’ble Supreme Court further quashed all the appointments made pursuant to the said advertisement and liberty was given to the State to issue fresh advertisement complying with the constitutional mandate and the rules.

6. Pursuant to the aforesaid order passed by the Hon’ble Supreme Court, the respondents published a fresh advertisement for filling-up of the Class-IV posts, vide Advertisement No.01/2025. The Pay-Scale fixed by the State is P.B-1 (520020200) and Grade Pay-1800. The minimum educational qualification has been prescribed in Paragraph 8 of the said Advertisement which is Matriculation. The same was in terms of the Resolution of the Finance Department, being Resolution No.1859 dated 02.09.2011. The petitioners are aggrieved by the aforesaid clause. The petitioners want that the said educational qualification clause is to be relaxed as the petitioners are nonmatriculate and they should also be given a chance to apply.

7. The respondents have brought to the notice of this

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2026:JHHC:248

Court, a Resolution No.1859 dated 02.09.2011, in which, as per Clause-5 (क) for Pay-Scale of 5200-20200 with Grade Pay of 1800, the minimum education qualification prescribed is Matriculate.

8. In this case, the Pay-Scale which is being fixed by the State for the Class-IV employees is 5200-20200 in Grade Pay1800, thus the advertisement prescribed the minimum education qualification to be Matriculation which is in term of the Resolution No.1859 dated 02.09.2011.

9. Since the Pay-Scale prescribed by the State in the Advertisement is 5200-20200 with Grade Pay of 1800, they are correct in fixing the educational qualification as Matriculation, for the proposed employee who are applying pursuant to the said advertisement. I find no illegality in action of the respondents whereby they have fixed the minimum education qualification to be Matriculate. Thus, no relief can be granted to the petitioners. Accordingly, this writ petition stands dismissed .

(ANANDA SEN, J.)

07.01.2026

S.K.D., cp2

Uploaded on 12.01.2026

4

Issues for consideration

1 issue framed by the court

AI extract

1.
Whether the petitioners, being non-matriculates qualified up to Class-8, are entitled to relaxation of the minimum educational qualification of Matriculation prescribed in fresh Advertisement No.01/2025 for Class-IV posts in the District of Palamau, so as to be allowed to apply for appointment.¶32
The court held
For the Class-IV pay scale of 5200-20200 with Grade Pay 1800 (P.B-1), the minimum educational qualification of Matriculation fixed in the fresh Advertisement No.01/2025 accords with Clause-5(क) of the Finance Department Resolution No.1859 dated 02.09.2011.ratio¶45

Cases cited

Colour shows how this judgement treated each authority

AI extract

Civil Appeal No.(s) 13950-13951 of 2024Referred¶39

Statutes considered

2 provisions across 2 enactments

AI extract

Constitution of IndiaArticle 14 and Article 16¶39
Resolution of the Finance DepartmentClause-5 (क)¶44

Procedural history

How this case reached the court

AI extract

Order under challenge
Fresh Advertisement No.01/2025 published by the respondents pursuant to the Supreme Court order, for filling up Class-IV posts at Pay Band-1 (pay scale 5200-20200, Grade Pay 1800), prescribing minimum educational qualification of Matriculation, against which the petitioners seek relaxation.¶40
Respondent authorities / State of Jharkhand
Prior proceeding
Advertisement No.01/2010 was published by the District of Palamau (dated 29 July 2010 per the judgment) to fill up Class-IV posts of Peon etc.¶39
Prior proceeding
The petitioners applied pursuant to Advertisement No.01/2010 but were not selected.¶39
Prior proceeding
Advertisement No.01/2010 was challenged in the Hon'ble Supreme Court in Civil Appeal Nos. 13950-13951 of 2024; the Supreme Court set aside the advertisement as violative of Articles 14 and 16 of the Constitution, quashed all appointments made pursuant to it, and gave the State liberty to issue a fresh advertisement complying with the constitutional mandate and the rules.¶39

Parties & counsel

AI extract

petitioner
Sarita Kumari¶4
Dilip Kr. Prasad
petitioner
Anand Kumar¶5
Dilip Kr. Prasad
petitioner
Md. Khalik¶6
Dilip Kr. Prasad
petitioner
Surendra Kumar¶7
Dilip Kr. Prasad
petitioner
Manesh Oraon¶8
Dilip Kr. Prasad
petitioner
Ramyad Oraon¶9
Dilip Kr. Prasad
petitioner
Naimuddin Ansari¶10
Dilip Kr. Prasad
petitioner
Kundal Prasad Gupta¶11
Dilip Kr. Prasad
petitioner
Pawan Kumar¶12
Dilip Kr. Prasad
petitioner
Md. Isaullah Roy¶13
Dilip Kr. Prasad
petitioner
Bikesh Paswan¶14
Dilip Kr. Prasad
petitioner
Rajesh Kumar¶15
Dilip Kr. Prasad
petitioner
Sanjay Kumar¶16
Dilip Kr. Prasad
respondent
The State of Jharkhand¶18
Ravi Kerketta, Deepika Jojowar, Rituraj
respondent
The Secretary, Department of Personnel Administrative Reforms and Rajbhasha, Govt. of Jharkhand¶19
Ravi Kerketta, Deepika Jojowar, Rituraj
respondent
The Commissioner, Palamau Division¶20
Ravi Kerketta, Deepika Jojowar, Rituraj
respondent
The Deputy Commissioner, Palamau¶23
Ravi Kerketta, Deepika Jojowar, Rituraj
respondent
The Deputy Collector (Establishment), Palamau¶24
Ravi Kerketta, Deepika Jojowar, Rituraj

Coram

AI extract

Ananda Senauthor¶26

Case details

As recorded by the court registry

Court: Jharkhand HC
Decided on: 7 Jan 2026 · January
Registered: 20 Dec 2025
Case no.: WPC/7739/2025
CNR: JHHC010434312025
Bench: Sri Ananda Sen
Disposal: Dismissed
Case type: W.P.(S)

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Cite this judgement

Sarita Kumari v. the State of Jharkhand, WPC/7739/2025 (JH), decided on 7 January 2026.

The High Court of Jharkhand publishes no neutral citation for this judgement — cite it by case number and date of decision.

Cases cited1

Civil Appeal No.(s) 13950-13951 of 2024Referred¶39

Open Authorities

Statutes2

Constitution of IndiaArticle 14 and Article 16
Resolution of the Finance DepartmentClause-5 (क)

View all statutes

Procedural history4

Fresh Advertisement No.01/2025 published by the respondents pursuant to the Supreme Court order, for filling up Class-IV posts at Pay Band-1 (pay scale 5200-20200, Grade Pay 1800), prescribing minimum educational qualification of Matriculation, against which the petitioners seek relaxation.Respondent authorities / State of Jharkhand
Advertisement No.01/2010 was published by the District of Palamau (dated 29 July 2010 per the judgment) to fill up Class-IV posts of Peon etc.
The petitioners applied pursuant to Advertisement No.01/2010 but were not selected.

View full history

Bench / Coram

Ananda Sen

Parties & counsel