Ashok Kumar Yadav v. State of Haryana

Ashok Kumar Yadav v. State of Haryana, AIR 1987 SC 454


Plaintiff: Ashok Kumar Yadav and others (Appellants)

Defendant: State of Haryana and others (Respondents)


Facts of the Case:

The case revolves around the selection process for the Haryana Civil Service (Executive Branch) and other Allied Services through the Haryana Public Service Commission (HPSC). A competitive examination was conducted in 1980, where the commission was accused of gross favoritism and arbitrariness in selecting candidates. The petitioners, including Ashok Kumar Yadav, contended that the viva-voce marks had been disproportionately inflated, thus favoring certain candidates.

The issue arose from the fact that the interview (viva-voce) carried a high weightage, constituting 200 marks out of a total of 600, while the written exam carried 400 marks. It was alleged that some members of the selection committee were biased, and certain candidates with connections to the members received favorable marks during the interviews. The petitioners, who performed well in the written examination but poorly in the interview, challenged the fairness of the selection process.

The petitioners also argued that the large weightage given to viva-voce marks created opportunities for favoritism and bias, undermining the merit-based selection process.


Issues Before the Court:

  1. Whether the high weightage of viva-voce marks in the selection process violated the principles of fairness, transparency, and equality.

  2. Whether the selection process conducted by the Haryana Public Service Commission was arbitrary and biased.

  3. Whether the petitioners were unfairly denied a fair opportunity due to the disproportionate allocation of marks in the interview process.

  4. Whether the involvement of certain biased members in the selection process compromised the integrity of the examination and selection procedure.


Decision of the Court:

The Supreme Court of India ruled that the selection process conducted by the Haryana Public Service Commission was indeed flawed. The court found that giving 200 marks out of 600 (one-third) for the viva-voce test was excessive and created a situation where the interview process could be misused to favor certain candidates. It held that this high weightage undermined the merit-based written examination and opened the door to bias and manipulation.

The court observed that the viva-voce should play a supplementary role in the selection process, helping assess the personality and demeanor of candidates. However, excessive reliance on it, as was the case in this selection process, was unjust and arbitrary. 

The court also expressed concern about the inclusion of biased members in the selection committee, which further tainted the fairness of the process. It ruled that all candidates should be evaluated fairly, and no undue advantage should be given to any candidate based on personal connections or favoritism.

As a result, the court ordered that the results of the viva-voce test be moderated and limited in its influence. The court reduced the weightage of viva-voce marks to a maximum of 12.2% of the total marks, ensuring that the majority of the weight was placed on the written examination. The court directed a re-evaluation of the selection process, ensuring fairness to all candidates and preventing arbitrary favoritism.


Case Analysis:

The Ashok Kumar Yadav v. State of Haryana case is significant for the principles of fairness, transparency, and meritocracy in public service examinations. The court’s ruling emphasized that while viva-voce tests are important in judging the personality and suitability of candidates for certain posts, they must not be given excessive importance, especially in written competitive examinations where merit should primarily be determined by objective performance.

Excessive Weightage of Viva-Voce Marks: The court's decision criticized the disproportionate weight given to viva-voce marks, observing that such high allocation opens up opportunities for bias. The ruling underscored that viva-voce, while valuable, should not overpower the written exam’s role in assessing candidates' knowledge and competence. The excessive weightage in this case allowed the possibility of favoritism, which could compromise the selection process.

Bias and Favoritism in Selection: A key aspect of the case was the potential for bias in the viva-voce process. The involvement of biased members in the interview panel was seen as undermining the credibility of the selection process. The court recognized that any arbitrary or prejudiced influence in the selection of public servants is detrimental to the public interest and violates the fundamental right to equality.

Principles of Fairness and Transparency: The case reaffirmed that public service commissions, being constitutional bodies, are bound by principles of fairness, transparency, and meritocracy. Any deviation from these principles, such as manipulating the weightage of interviews to favor certain candidates, was deemed unconstitutional.

The court's intervention in reducing the weightage of viva-voce marks and ordering a review of the selection process reinforced the importance of fair and impartial selection in public service recruitment. The ruling also highlighted that public service commissions must ensure that their selection processes are free from any arbitrariness, bias, or favoritism, maintaining the integrity of the public service.


Importance of the Case:

  1. Limitation on Viva-Voce Marks: The case established a precedent that the weightage of viva-voce marks in competitive examinations should be reasonably limited to ensure that merit-based selection through written tests is not undermined. This is crucial in ensuring that objective standards are maintained in the selection of public servants.  

  2. Judicial Oversight on Public Service Recruitment: The ruling demonstrated the judiciary's willingness to intervene in public service recruitment processes to ensure fairness, transparency, and adherence to the constitutional principles of equality and meritocracy.

  3. Bias and Favoritism in Public Service Selection: The case set a critical standard against favoritism and bias in public service appointments. It reinforced the idea that any process which allows undue advantage to certain candidates based on personal connections or bias is unconstitutional.

  4. Merit-Based Public Employment: The court underscored the importance of maintaining meritocracy in public employment. It emphasized that objective evaluation methods, such as written exams, should carry more weight in the selection process compared to subjective elements like interviews.

This case remains an important milestone in the development of law governing public service recruitment in India, providing guidance on maintaining the balance between written examinations and interviews, and ensuring that the process remains free from bias and arbitrary decisions.

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