The Administrative Officer Vs Dr. Kusuma Shamanoor — Karnataka HC (2026) — LawSathi Research

The Administrative Officer Vs Dr. Kusuma Shamanoor — Karnataka HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

Appeals in W.A.Nos.1330/2025, 1009/2025 and 1373/2025 allowed; impugned common order dated 03.04.2025 in W.P.No.10465/2023 set aside; writ petition filed by Nagaraja S. consequently dismissed. W.A.No.1021/2025 dismissed; pending interlocutory applications, if any, disposed of.

Issue for consideration

Whether a candidate who did not submit his Bachelor's Degree certificate and marks sheet along with his application on or before the last date (23.02.2019) could be awarded marks for the Bachelor's Degree, given Clause-19 of the recruitment Notification barring consideration of any document given after the last date. +1 more

Court's answer

Clause-19 provides that no marks shall be awarded in respect of any document not submitted along with the application on or before the last date prescribed; Nagaraja S. having admittedly not produced the Bachelor's Decree Certificate with the application or even on the last date, he was not awarded any mark out of the maximum 10 marks for Bachelor's Degree.

Ratio / Principle

Where the recruitment process clearly delineated the method of assessment, the Writ Court could not have substituted another method; by directing reconsideration of the Bachelor's Decree and reassessment of marks for academic qualification, the Writ Court undertook a substitution that cannot be countenanced.

Key takeaways

Regarding W.A.No.1021/2025: the underlying writ petition (W.P.No.15646/2024), filed against the show-cause notice, stands dismissed as per the order above; the appellant had already filed her reply and an inquiry officer had been appointed for conducting the inquiry in accordance with the law, and accordingly that appeal is dismissed.ratio¶¶129

Detailed headnote1 paragraphs

Recruitment – Assistant Professor (Physical Education), University of Agricultural and Horticultural Sciences/Keladi Shivappa Nayaka University, Shivamogga – Notification dated 24.01.2019; last date for applications 23.02.2019 – Clause-19 of Notification: late/incomplete applications and applications without prescribed fees liable to rejection; additional documents/certificates/records given after the last date not to be considered for award of marks – Nagaraja S. did not submit Bachelor's Degree and marks sheet with his application; awarded zero of maximum 10 marks for Bachelor's Degree; secured 64.330 marks – Dr. Kusuma Shamanoor secured highest marks (66.425), declared Selected Candidate, joined and continued in service – Single Judge (common order dated 03.04.2025 in W.P.No.10465/2023 C/w W.P.No.15646/2024) had directed reconsideration of Nagaraja's late-submitted B.A. decree and reassessment of inter se merit – Division Bench held: where the recruitment process clearly delineates the method of assessment, the Writ Court cannot substitute another method; no marks awardable for documents not submitted by the prescribed last date – Appeals W.A.Nos.1330/2025, 1009/2025, 1373/2025 allowed; impugned order set aside; Nagaraja's writ petition dismissed – W.A.No.1021/2025 (filed against show-cause notice to initiate inquiry on Nagaraja's complaint; proceedings initiated under Rule 11, Karnataka Civil Services (Classification, Control and Appeal) Rules, 1957) dismissed; appellant had filed reply and inquiry officer appointed to conduct inquiry in accordance with law. Bench: Justice D K Singh (authoring judge) and Justice T.M. Nadaf; decided 06.07.2026.

Procedural history

How this case reached the court

AI extract

Order under challenge
Common order of the learned Single Judge (Writ Court) in W.P.No.10465/2023 C/w W.P.No.15646/2024: held that Nagaraja S. possessed Bachelor's, Master's and Doctorate degrees in Physical Education and a Graduation degree in Sociology, and directed reconsideration of his Bachelor of Arts decree and reassessment of inter se merit between Nagaraja S. and Dr. Kusuma Shamanoor.¶¶97
Writ Court (learned Single Judge), High Court of Karnataka · 03.04.2025
Prior proceeding
Notification dated 24.01.2019 issued by the appellant-University inviting applications for recruitment to posts of Assistant Professor, inter alia, in Physical Education; last date for submitting applications was 23.02.2019.¶¶103
Prior proceeding
Clause-19 of the Notification provided that applications received after the last date, incomplete applications and applications without prescribed fees were liable to be rejected, and that additional documents/certificates/records given after the last date would not be considered for award of marks.¶¶105
Prior proceeding
Selection based on academic qualifications and interview (maximum 10 marks for Bachelor's Degree): Nagaraja S. did not submit his Bachelor's Degree and marks sheet with his application, was awarded zero marks for Bachelor's Degree and secured 64.330 marks.¶¶110
Prior proceeding
Dr. Kusuma Shamanoor secured the highest marks (66.425), was declared the Selected Candidate for the post of Assistant Professor (Physical Education), joined service and continued on the post.¶¶113
Prior proceeding
Nagaraja S. filed W.P.No.10465/2023 challenging the selection of Dr. Kusuma Shamanoor; the Writ Court held that, if marks were given for his Bachelor's Degree, he would outweigh her, and directed reconsideration of his Bachelor of Arts decree and reassessment of inter se merit.¶¶117
Prior proceeding
Dr. Kusuma Shamanoor filed W.P.No.15646/2024 against a show-cause notice issued to her to initiate inquiry on the complaint of Sri. Nagaraja S.¶¶102