Supreme Court Upholds Interview Cut-Off for Judicial Appointments, Dismisses Challenge to Viva-Voce Minimum Marks

Case Snapshot

Case Name: Manoj Goyal v. Rajasthan High Court & Ors.

Citation: 2026 INSC 699

Bench: Justice Prasanna B. Varale

Date of Judgment: July 13, 2026

Area of Law: Service Law, Judicial Appointments, Constitutional Law

The Judgment in One Line

Candidate who participated in selection process with open eyes cannot challenge viva-voce cut-off after being unsuccessful; Shetty Commission recommendations are only guidelines.

Why This Judgment Matters

This landmark judgment clarifies that the Shetty Commission's recommendations on judicial recruitment are guidelines, not binding statutory mandates. The Supreme Court upheld the validity of a 25% minimum cut-off in interviews for Additional District Judge appointments, rejecting the argument that such a cut-off violates the Commission's recommendations. The Court also reaffirmed that candidates who participate in selection processes without protest cannot challenge the rules after being unsuccessful—the doctrine of estoppel applies. The judgment preserves administrative finality, protecting appointments finalized over a decade ago from being disturbed.

Background

The Rajasthan Judicial Service Rules, 2010 originally did not prescribe minimum qualifying marks for the viva-voce. In June 2011, Rule 41 was amended to mandate a minimum of 25% marks in the interview. The appellant participated in the 2011 recruitment process, secured 161/250 marks (64.4%) in the written exam, and was called for interview. He scored only 7 out of 30 in the viva-voce—0.5 marks short of the 25% threshold (7.5 marks). Despite ranking 11th in aggregate merit for 39 vacancies, he w

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