Legal Review and Analysis of Leelavathi N & Ors Etc vs The State of Karnataka & Ors Etc 2025 INSC 1242

1. Heading of the Judgment

Case Name: Leelavathi N. & Ors. Etc. vs. The State of Karnataka & Ors. Etc.
Citation: 2025 INSC 1242
Court: Supreme Court of India
Jurisdiction: Civil Appellate Jurisdiction
Judges: Hon'ble Mr. Justice J.K. Maheshwari and Hon'ble Mr. Justice Vijay Bishnoi
Date of Judgment: October 16, 2025

2. Related Laws and Sections

This judgment extensively deals with the following legal provisions and precedents:

• The Administrative Tribunals Act, 1985:
  Section 15: Defines the exclusive jurisdiction of State Administrative Tribunals over service matters, including recruitment to civil posts.
  Section 22: Empowers Tribunals to regulate their own procedure, guided by natural justice.
  Section 24: Lays down conditions for passing interim orders by the Tribunal.
  Sections 35 & 36: Empower the government to make rules for the efficient functioning of Tribunals.

• The Constitution of India:
  Article 226: Power of High Courts to issue certain writs.
  Article 227: Power of superintendence over all courts by the High Court.
  Article 142: Power of the Supreme Court to pass any decree or order to do complete justice.

• Key Legal Precedents Cited:
  L. Chandra Kumar vs. Union of India & Ors., (1997) 3 SCC 261 (Constitution Bench)
  Rajeev Kumar & Anr. vs. Hemraj Singh Chauhan & Ors., (2010) 4 SCC 554
  T.K. Rangarajan vs. Government of T.N. & Ors., (2003) 6 SCC 581
  Nivedita Sharma vs. Cellular Operators Association of India & Ors., (2011) 14 SCC 337
  Radha Krishan Industries vs. State of Himachal Pradesh & Ors., (2021) 6 SCC 771

3. Basic Judgment Details

This case originated from a recruitment process for 15,000 Graduate Primary Teacher posts in Karnataka. A dispute arose when married women candidates from the OBC category were placed in the general merit list because they submitted their father's income-cum-caste certificate instead of their husband's. Some of these candidates directly filed writ petitions before the Karnataka High Court, which a Single Judge allowed. This led to a new select list being published, excluding some initially selected candidates. The excluded candidates and the State appealed before a Division Bench, which set aside the Single Judge's order, holding that the writ petitions were not maintainable as an alternative remedy existed before the Karnataka State Administrative Tribunal (KSAT). The present appeals before the Supreme Court were filed by both sets of aggrieved candidates.

4. Core Principle and Analysis of the Judgment

The Central Legal Issue

The core legal question before the Supreme Court was whether the High Court, under Article 226 of the Constitution, was justified in entertaining writ petitions concerning a service matter when an efficacious alternative remedy was available before the Karnataka State Administrative Tribunal (KSAT).

In-Depth Analysis of the Court's Reasoning

A. The Primacy of Alternate Remedy and the L. Chandra Kumar Doctrine

The Supreme Court firmly reaffirmed the constitutional scheme established by the Constitution Bench in L. Chandra Kumar (supra). The Court analyzed this precedent in depth, highlighting the following key principles:

• Tribunals, like the KSAT, are the court of first instance for service disputes falling within their jurisdiction under the Administrative Tribunals Act, 1985.

• It is not open for litigants to directly approach the High Court,
  even if they are challenging the vires of a statutory legislation,
  except when the challenge is to the very legislation under which the Tribunal is created.

• The High Court's role under Articles 226/227 is that of a supervisory body exercising judicial review over the orders of the Tribunal, not as a primary court of adjudication for service matters.

B. Distinguishing Exceptional Circumstances: The Inapplicability of T.K. Rangarajan

The Court then addressed the Single Judge's reliance on T.K. Rangarajan (supra), where the High Court had entertained a writ petition concerning the dismissal of two lakh employees, deeming it an "unprecedented extraordinary situation." The Supreme Court made a critical distinction:

• The situation in T.K. Rangarajan was truly exceptional, involving mass dismissals that would have overwhelmed the tribunal, rendering it incapable of rendering effective justice.

• In contrast, the present case involved a dispute concerning the eligibility and certificates of only 481 candidates in a recruitment process. The Court held that such disputes over certificate validity are a common feature of recruitment and do not constitute an "unprecedented extraordinary situation."

• The Supreme Court went so far as to remark that the ruling in T.K. Rangarajan was, at best, an order passed under Article 142 to do complete justice in that unique case and did not lay down a binding principle that dilutes the L. Chandra Kumar doctrine.

C. The KSAT as an Effective and Empowered Forum

The Supreme Court conducted a thorough review of the Administrative Tribunals Act, 1985, and the corresponding Karnataka rules to demonstrate that the KSAT is a fully equipped forum. The Court emphasized that the KSAT has:

• Exclusive jurisdiction over service matters (S.15).

• The power to regulate its own procedure (S.22) and pass interim orders (S.24), even in urgent circumstances.

• The power to punish for its contempt.

• A statutory mandate to decide cases expeditiously, with rules prescribing a timeline of six months.
  The Court concluded that the statutory remedy before the KSAT is not merely an alternative but an effective and efficacious one, specifically designed to provide speedy relief in service matters.

Final Outcome and Supreme Court's Directions

The Supreme Court dismissed all the appeals and upheld the Division Bench's judgment. The Court issued the following consequential directions:

1. The interim orders passed by the Supreme Court during the pendency of the appeals (staying appointments, etc.) were made absolute.

2. The matter was relegated back to the KSAT for a fresh decision on merits.

3. The KSAT was directed to make every endeavor to decide the applications expeditiously, preferably within six months from the date of filing.

4. The 500 posts that were kept reserved pursuant to an earlier Supreme Court order were directed to be filled as per the final judgment of the KSAT.

5. The Supreme Court clarified that it had not expressed any opinion on the merits of the case (i.e., whether a married woman's caste/income should be determined by her father's or husband's certificate) and had only decided the issue of the maintainability of the writ petitions before the High Court.

5. MCQs Based on the Judgment

Question 1: In the case of Leelavathi N. vs. State of Karnataka (2025 INSC 1242), what was the primary legal principle reaffirmed by the Supreme Court regarding the jurisdiction of High Courts in service matters?

A. High Courts have unlimited discretion to entertain any service dispute under Article 226.
B. Tribunals are the preferred forum, but High Courts must always intervene if fundamental rights are affected.
C. In service matters covered by the Administrative Tribunals Act, litigants cannot directly approach the High Court and must first avail the remedy before the Tribunal.
D. A High Court's Single Judge bench has the final authority to decide on the maintainability of a writ petition.

C. In service matters covered by the Administrative Tribunals Act, litigants cannot directly approach the High Court and must first avail the remedy before the Tribunal.

Question 2: The Supreme Court distinguished the precedent set in T.K. Rangarajan vs. Government of T.N. from the facts of the Leelavathi case. What was the key distinguishing factor?

A. The T.K. Rangarajan case involved a dispute over educational qualifications, not caste certificates.
B. The situation in T.K. Rangarajan was deemed an "unprecedented extraordinary situation" involving mass dismissals, whereas the Leelavathi case involved a dispute concerning a limited number of candidates in a recruitment process.
C. The T.K. Rangarajan case was decided by a Constitution Bench, while Leelavathi was decided by a Division Bench.
D. The T.K. Rangarajan case did not involve the question of alternative remedy.

B. The situation in T.K. Rangarajan was deemed an "unprecedented extraordinary situation" involving mass dismissals, whereas the Leelavathi case involved a dispute concerning a limited number of candidates in a recruitment process.