Legal Review and Analysis of Sanjay Kumar Mishra & Ors vs District Judge Ambedkar Nagar Special Leave Petition C No14980 of 2024

1. Heading of the Judgment

Case Title: Sanjay Kumar Mishra & Ors. vs. District Judge, Ambedkar Nagar (U.P.)
Citation: Civil Appeal No. __ of 2025 [@Special Leave Petition (C) No.14980 of 2024]
Court: Supreme Court of India
Bench: Hon'ble The Chief Justice, B.R. Gavai, J., and K. Vinod Chandran, J.
Date: October 17, 2025

2. Related Laws and Rules

The judgment primarily interprets and applies the following rule:
Rule 12 of the Uttar Pradesh State District Court Staff Rules, 1953 (or analogous rules): This rule governs the maintenance of a wait list for Class IV posts. The key phrase interpreted by the Court is "reasonable dimension" concerning the size and validity period of such a wait list.

3. Basic Judgment Details

This civil appeal arose from a Special Leave Petition challenging the orders of the Allahabad High Court. The appellants, four Class IV employees appointed in the District Judgeship of Ambedkar Nagar in 2001, were terminated in 2008. The termination was on the grounds that their appointments were made against six posts that were in excess of the twelve vacancies originally advertised. Both the Single Judge and the Division Bench of the High Court had upheld the termination.

4. Core Principle and Analysis of the Judgment

The Primary Issue

The central legal question was whether appointments can be validly made from a wait list against vacancies that arise in excess of the number originally advertised, and if so, within what timeframe such appointments remain permissible.

Interpretation of the Law and Precedent

The Supreme Court's analysis centered on a precedent, Naseem Ahmad v. State of Uttar Pradesh (2011) 2 SCC 734, which interpreted the same Rule 12.
The Advertisement's Rider is Key: The Court noted that the original advertisement itself contained a crucial rider stating that the number of posts "may be increased or decreased." This language indicated the appointing authority's intention to maintain a functional wait list for future vacancies.
Meaning of "Reasonable Dimension": The Court heavily relied on the interpretation from Naseem Ahmad, which held that a wait list of "reasonable dimension" is one that is adequate to meet vacancies arising within a reasonable period, specifically in the year of recruitment or the immediately succeeding year. This was to prevent the wait list from becoming arbitrary or vitiated.
Application to the Present Case: The Court found the situation "almost identical" to Naseem Ahmad. The appellants were appointed from the wait list in 2001. The fact that the next advertisement for similar posts was only issued in 2008 proved that vacancies had arisen within the intervening period, well within the "reasonable period" envisaged by the rule and the precedent.

The Supreme Court's Reasoning and Findings

The Court concluded that the High Court had erred in its judgment for two primary reasons:
Ignoring the Advertisement's Specific Rider: The High Court failed to give legal weight to the explicit clause in the advertisement that allowed for the number of vacancies to change.
Misapplication of Law: The High Court's decision was contrary to the settled law established in Naseem Ahmad, which expressly permitted such appointments from a wait list against future vacancies arising within a reasonable timeframe.Consequently, the Supreme Court held that the appointments of the appellants were valid and their termination in 2008 was unjustified.

5. Final Outcome and Directions

While allowing the appeal and setting aside the termination, the Supreme Court recognized the practical hardship: the appellants had been out of service for nearly 17 years. In light of this, and since the appellants had only worked for 8 years before termination, the Court issued the following nuanced relief:
Reinstatement: Appellants who have not yet reached the age of superannuation shall be accommodated in existing Class IV vacancies in the same judgeship. If no vacancies exist, they shall be appointed to supernumerary posts to be adjusted against future vacancies.
Pension for Retired Appellants: Appellants who have already crossed the retirement age shall be entitled to a minimum pension.
Service Benefits: The appellants who are reinstated will not get seniority but their past 8 years of service will be counted for determining pensionable service. They will be granted a minimum pension upon retirement.
No Back Wages or Notional Service: The 17-year period when they were not working will not be counted for any service benefits, back wages, or notional service.
Case-Specific Relief: The directions were explicitly made applicable only to the four appellants and not to be treated as a general precedent.

6. Multiple Choice Questions  Based on the Judgment

Question 1: What was the key legal principle, as established in the Naseem Ahmad case, that the Supreme Court applied in Sanjay Kumar Mishra vs. District Judge?
a) Termination of government employees requires a three-month notice period.
b) A wait list of "reasonable dimension" can be used to fill vacancies arising in the recruitment year or the immediately succeeding year.
c) All advertisements for government jobs must mention the exact number of vacancies.
d) Class IV employees cannot be promoted to the Ministerial Cadre.

b) A wait list of "reasonable dimension" can be used to fill vacancies arising in the recruitment year or the immediately succeeding year.

Question 2: What specific relief was granted by the Supreme Court to the appellants who had already crossed the retirement age?
a) Full back wages for 17 years.
b) Reinstatement with full seniority.
c) Entitlement to a minimum pension.
d) A compensatory lump-sum amount.

c) Entitlement to a minimum pension.