Legal Analysis: Dr. Manoj Kumar Rawat v. State of UP & Ors

Citation: 2026 INSC 508
Court: Supreme Court of India
Bench: A Division Bench comprising Justice J.K. Maheshwari and Justice Atul S. Chandurkar
Date of Decision: May 19, 2026
Nature of Case: Civil Appeal arising out of SLP (C) No. 15989 of 2025

Synopsis

The appellant, a waitlisted candidate for the post of Principal in non‑Government aided colleges in Uttar Pradesh, was initially recommended for appointment to a college in Ballia on 03.08.2022 under the Uttar Pradesh Higher Education Services Commission Act, 1980 (the “old Act”). He did not join and, after about ten months, requested a change of posting to Meerut College. The Director rejected this request on 17.08.2023. On 21.08.2023, the Uttar Pradesh Education Service Selection Commission Act, 2023 (the “New Act”) came into force, repealing the old Act. Nevertheless, on 13.12.2023 and 12.01.2024, the authorities issued fresh orders recommending the appellant to Meerut College. The High Court quashed those orders, holding that after the repeal and the earlier rejection, the appellant had no right to be considered under the old Act. The Supreme Court dismissed the appeal, affirming that the “act done” under the old Act was only the initial recommendation; the subsequent orders after the New Act came into force were without jurisdiction. The Court also held that the word “otherwise” in Section 13(4) of the old Act must be construed ejusdem generis and does not cover a candidate’s voluntary non‑joining or request for change of place.

1. Basic Information of the Judgment

• Case Title: Dr. Manoj Kumar Rawat v. State of Uttar Pradesh & Ors.

• Citation: 2026 INSC 508

• Civil Appeal No.: Arising out of SLP (C) No. 15989 of 2025

• Bench: Division Bench (Justice J.K. Maheshwari and Justice Atul S. Chandurkar)

• Date of Decision: May 19, 2026

• Court: Supreme Court of India (Civil Appellate Jurisdiction)

• Impugned Order: Judgment of the Division Bench of the Allahabad High Court dated 05.05.2025 affirming the Single Judge’s order quashing the appointment orders.

2. Legal Framework

Major Laws and Provisions Involved

• Uttar Prades

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