Legal Review and Analysis of Ravi Oraon & Ors vs The State Of Jharkhand & Ors 2025 INSC 1212

1. Heading of the Judgment

Case Title: RAVI ORAON & ORS. vs. THE STATE OF JHARKHAND & ORS.
Citation: 2025 INSC 1212
Court: Supreme Court of India
Jurisdiction: Civil Appellate Jurisdiction
Civil Appeal Nos.: 11748, 11749, and 11750 of 2025
Judges: Hon'ble Mr. Justice Dipankar Datta and Hon'ble Mr. Justice K.V. Viswanathan
Date of Judgment: October 09, 2025

2. Related Laws and Sections

The judgment primarily interprets and applies the following rules and legal principles:

• The Jharkhand Primary School Teacher Appointment Rules, 2012:
  Rule 4: This rule falls under Chapter 2 (Teacher Eligibility Test) and prescribes the eligibility criteria, including the minimum percentage of marks required in the intermediate examination (Class XII). It provides a 5% marks relaxation for candidates belonging to Scheduled Castes, Scheduled Tribes, and disabled categories.
  Rule 21: This rule falls under Chapter 3 (Appointment) and details the procedure for preparing the merit list for final selection. It specifically states that for calculating the "educational merit point," marks obtained in an "additional subject" shall not be included.

• The Constitution of India:
  Article 309: The proviso to this article empowers the Governor to make rules regulating the recruitment and conditions of service of persons appointed to public services, which is the source of authority for the 2012 Rules.

• Principles of Natural Justice: The judgment is heavily based on the fundamental principle that no person shall be condemned unheard. It underscores that an order based on grounds not mentioned in the show-cause notice is a violation of due process.

3. Basic Judgment Details

• Parties: Appellants - Ravi Oraon, Premial Hembrom, and Surendra Munda (appointed as Intermediate Trained Teachers); Respondents - The State of Jharkhand and its Departmental Officials.

• Nature of Case: Civil Appeals challenging the common judgment of the Jharkhand High Court which had upheld the termination of the appellants' services.

• Core Dispute: The appellants, belonging to the Scheduled Tribe category, were terminated from their posts as teachers on the grounds that they did not possess the minimum required 40% marks in their intermediate examination and that their graduation certificates were invalid.

• Impugned Judgment: The Division Bench of the High Court had reversed the decisions of the Single Judge and upheld the terminations, ruling that the method of calculating marks under Rule 21 (which excludes vocational subject marks) was applicable to determine eligibility.

4. Core Principle and Analysis of the Judgment

The Central Issue: Erroneous Application of Rules and Violation of Due Process

The Supreme Court was tasked with deciding two primary issues: first, whether the method of calculating marks for determining eligibility was correct, and second, whether the termination process followed the principles of natural justice.

The Supreme Court's In-Depth Analysis and Reasoning

The Court allowed the appeals, setting aside the High Court's judgment and the termination orders. Its reasoning was founded on a clear distinction between the stages of eligibility and selection, and a strict adherence to procedural fairness.

1. Critical Distinction: Rule 4 (Eligibility) vs. Rule 21 (Merit List Preparation)
   The Court identified a "prodigious error" in the approach of the Department and the High Court. It held that Rule 4 and Rule 21 operate in completely different domains:
   Rule 4 (Chapter 2): This rule exclusively governs the eligibility of a candidate to even appear for the Teacher Eligibility Test (TET). It prescribes the minimum qualification marks but is silent on excluding marks from vocational subjects for this purpose.
   Rule 21 (Chapter 3): This rule comes into play after a candidate is found eligible and has cleared the TET. It provides a specific formula for calculating the "educational merit point" for the purpose of preparing the merit list for final appointment. The exclusion of marks from "additional subjects" is mandated only at this subsequent stage of selection and ranking, not for determining the threshold eligibility.The Court concluded that applying Rule 21 to disqualify the appellants at the eligibility stage was a fundamental legal error. For determining if they had secured the minimum 40% marks, the calculation method provided on their mark sheets (which included bonus marks from vocational subjects) was the correct and only applicable method.

2. Violation of Principles of Natural Justice: Condemnation on Un-Noticed Grounds
   The Court strongly condemned the termination process as a "course of action which shocks our conscience." The analysis was as follows:
   The show-cause notices accused the appellants of not securing the general category benchmark of 45% marks.
   In their replies, the appellants successfully defended themselves by pointing out their entitlement to a 5% relaxation (requiring only 40%) and demonstrating that they had secured above 40% as per their mark sheets.
   Instead of accepting this defense or issuing a fresh notice on a new charge, the Department terminated their services on a completely different ground—that they had not secured 40% marks when vocational subject marks were excluded.
   The Court held this to be a gross violation of natural justice. A person cannot be penalized on a charge they were never asked to answer. The termination was therefore rendered "wholly unsustainable and vitiated."

5. Final Outcome and Supreme Court Directions

The Supreme Court allowed the appeals and issued the following comprehensive relief:

• The judgments of the Division Bench of the High Court were set aside.

• The termination orders of all three appellants were quashed.

• For Appellants Ravi Oraon and Premial Hembrom:
  They were to be reinstated and treated as being in continuous service from their original appointment dates (December 2015).
  They were granted full arrears of pay and seniority from their initial dates of appointment.
  However, the period they were not actually on duty would not count for acquiring teaching experience for promotions.

• For the Deceased Appellant Surendra Munda:
  As he had passed away, reinstatement was not possible.
  His heirs were granted full arrears of pay from his termination until his death.
  He was deemed to have died-in-harness, making his heirs eligible to apply for compassionate appointment, which the authorities were directed to consider on merit.

6. Multiple Choice Questions (MCQs) Based on the Judgment

Question 1: In Ravi Oraon v. State of Jharkhand (2025 INSC 1212), the Supreme Court held that Rule 21 of the Jharkhand Primary School Teacher Appointment Rules, 2012, which excludes marks from additional subjects, is applicable at which stage of the recruitment process?
(a) At the stage of determining eligibility to appear in the Teacher Eligibility Test.
(b) At the stage of preparing the merit list for final appointment.
(c) At both the eligibility and the final appointment stages.
(d) It is not applicable to candidates from reserved categories.

(b) At the stage of preparing the merit list for final appointment.

Question 2: The Supreme Court found the termination of the teachers in the aforementioned case to be a violation of the principles of natural justice primarily because?
(a) They were not given a personal hearing before the termination.
(b) The termination order was passed by an authority not competent to do so.
(c) They were condemned on a ground that was not part of the original show-cause notice.
(d) The inquiry was not conducted by an impartial committee.

(c) They were condemned on a ground that was not part of the original show-cause notice.