Manikanta M v. Union Public Service Commission

Karnataka HC25 Jun 2025WP/13770/2025

Case brief

AI extract

What is this about?

Karnataka HC, 25-06-2025, H.T. Narendra Prasad J., WP 13770/2025 (S-RES); UPSC/Ministry of MSME recruitment — Assistant Director Grade-II (IEDS) (Food), Advt. 10/2024, Vacancy 24051023625; candidature rejected for deficient educational qualifications; writ under Art. 226/227 dismissed as not maintainable at first instance for 'service matters' of a civil servant per L. Chandra Kumar v. Union of India, 1997(2) SCR 1186; petition disposed with liberty to approach CAT/appropriate forum; merits untouched.

What did the court decide?

Liberty reserved to the petitioner to approach the appropriate legal forum (Central Administrative Tribunal); the merits of the rejection of candidature were not adjudicated. ¶¶36

Manikanta M Vs Union Public Service Commission — Writ and Judicial Review | Karnataka HC (2025)

What the court decided

AI extract

Outcome

Liberty reserved to the petitioner to approach the appropriate legal forum (Central Administrative Tribunal); the merits of the rejection of candidature were not adjudicated.

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Issue for consideration

Maintainability: whether a civil servant aggrieved in 'service matters' (here, rejection of candidature for a government post) may bring the grievance before the High Court under Articles 226 and 227 of the Constitution, or must approach the Central Administrative Tribunal. +1 more

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Court's answer

The grievance of a civil servant in respect of 'service matters' cannot be adjudicated by a writ court acting as the court of first instance; relying on L.Chandra Kumar vs. Union of India, 1997(2) SCR 1186, the petitioner had to approach the Central Administrative Tribunal.

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Ratio / Principle

In view of the above, the writ petition was disposed of with liberty reserved to the petitioner to approach the appropriate legal forum.

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Detailed headnote1 paragraphs

High Court of Karnataka (Bengaluru), Oral Order of Justice H.T. Narendra Prasad dated 25 June 2025 in W.P. No. 13770 of 2025 (S-RES). Manikanta M. challenged the respondents' rejection of his candidature for the post of Assistant Director Grade-II (IEDS) (Food), Office of the Development Commissioner (MSME), under Advertisement No. 10/2024 and Vacancy No. 24051023625 (Annexure B, May 2024), on the ground of alleged deficiency in educational qualifications, invoking Articles 226 and 227 of the Constitution. On the Central Government Counsel's preliminary objection that the petitioner, being a civil servant, should approach the Central Administrative Tribunal, the Court — placing reliance on L.Chandra Kumar vs. Union of India and others, 1997(2) SCR 1186 — held that grievances in respect of 'service matters' cannot be adjudicated by a writ court as the court of first instance, and disposed of the writ petition reserving liberty to the petitioner to approach the appropriate legal forum. The merits of the educational-qualification objection were not examined.

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NC: 2025:KHC:22122 WP No. 13770 of 2025

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HC-KAR

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IN THE HIGH COURT OF KARNATAKA AT BENGALURU

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DATED THIS THE 25^TH DAY OF JUNE, 2025

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BEFORE

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THE HON'BLE MR JUSTICE H.T. NARENDRA PRASAD

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WRIT PETITION NO. 13770 OF 2025 (S-RES)

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BETWEEN:

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MANIKANTA M S/O DODDAMUNIYAPPA AGED ABOUT 28 YEARS R/O YALAGONDANAHALLI MULABAGILU, KOLAR 563127.

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…PETITIONER

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(BY SRI. AHAAN MOHAN., ADVOCATE)

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AND:

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UNION PUBLIC SERVICE COMMISSION

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THROUGH ITS SECRETARY DHOLPUR HOUSE SHAHAJAN ROAD NEW DELHI 110069.

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Digitally signed by HEMALATHA A Location: HIGH COURTOF KARNATAKA

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UNION OF INDIA

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THROUGH ITS SECRETARY MINISTRY OF MICRO SMALL AND MEDIUM ENTERPRISES (MSME) GOVERNMENT OF INDIA UDYOG BHAWAN NEW DELHI-110011

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…RESPONDENTS (BY SRI. B PRAMOD, CGC FOR RESPONDENTS)

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THIS WRIT PETITION IS FILED UNDER ARTICLES 226 AND 227 OF THE CONSTITUTION OF INDIA PRAYING TO QUASH THE IMPUGNED ACTION OF THE RESPONDENTS IN

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2 - NC: 2025:KHC:22122 WP No. 13770 of 2025

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HC-KAR

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REJECTING THE PETITIONERS CANDIDATURE FOR THE POST OF ASSISTANT DIRECTOR GRADE-II (IEDS) (FOOD) IN OFFICE OF THE DEVELOPMENT COMMISSIONER (MSME), MINISTRY OF MICRO, SMALL AND MEDIUM ENTERPRISES IN ADVERTISEMENT NO. 10/2024 AND VACANCY NO. 24051023625 (ANNEXURE B) DATED MAY 2024, ON THE GROUND OF ALLEGED DEFICIENCY IN EDUCATIONAL QUALIFICATIONS AND ETC.

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THIS PETITION, COMING ON FOR PRELIMINARY HEARING, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

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CORAM: HON'BLE MR JUSTICE H.T. NARENDRA PRASAD

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ORAL ORDER

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At the outset, learned CGC raised a preliminary objection regarding maintainability of the writ petition on the ground that the petitioner is a Civil Servant and

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he has to approach the Central Administrative Tribunal.

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The grievance in respect of the ‘service matters’ cannot be a subject matter of adjudication at the hands of a writ Court, as the court of first instance, in the light of the decision of the Apex Court in the case

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NC: 2025:KHC:22122 WP No. 13770 of 2025

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HC-KAR

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of L.Chandra Kumar vs. Union of India and others

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reported in 1997(2) SCR 1186.

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