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Supreme Court of India 2019-09-12 allowed

THE STATE OF RAJASTHAN vs TRILOK RAM

Bench: 2 — Sanjay Kishan Kaul, K.M. Joseph

In Brief

The State of Rajasthan advertised for teacher positions in 2013, stipulating that candidates must possess the required B.S.T.C. qualification on the application deadline. Trilok Ram, who was still completing his qualification, applied relying on a proviso to the recruitment rules that allowed candidates appearing in the B.S.T.C. examination to apply. After securing sufficient marks, he was excluded from the final selection list. The High Court upheld his claim, finding the proviso survived a 2011 amendment to the recruitment rules. The Supreme Court reversed this, holding that when a statutory rule is substituted, it entirely ceases to exist—including any provisos—unless expressly saved. Since the proviso was not re-inserted after the 2011 substitution, candidates had to possess qualifications on the application deadline. The appeal was allowed and the High Court judgment set aside.",

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Education Law Recruitment Teacher Selection Statutory Interpretation Substitution of Rules Proviso Repeal and Re-enactment Administrative Law

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