Civil services recruitment rule upheld: resignation before reappearing was found consistent with training discipline and constitutional equality.

A service rule requiring a candidate already allocated and appointed to a service to resign before reappearing for the civil services examination was treated as a valid proviso, not an ultra vires rewrite of the eligibility scheme. The Supreme Court accepted that the restriction supported training discipline, effective administration, and the object of selecting committed probationers, and therefore was neither arbitrary nor unreasonable. It also held that the rule applied through an intelligible classification between distinct cadres and did not create hostile discrimination under Articles 14, 16 or 335, including in relation to Scheduled Caste and Scheduled Tribe candidates.

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Issues: (i) Whether the second proviso to Rule 4 of the Civil Services Examination Rules and the proviso to Rule 17 were ultra vires Regulation 4(iii-a) of the IAS (Appointment by Competitive Examination) Regulations, 1955; (ii) whether the impugned proviso was arbitrary, unreasonable, or lacking nexus with the object of the recruitment scheme; (iii) whether the proviso offended Articles 14, 16 and 335 of the Constitution of India by creating hostile discrimination, including as against candidates from Scheduled Castes and Scheduled Tribes and between Group 'A' and Group 'B' services.

Issue (i): Whether the second proviso to Rule 4 of the Civil Services Examination Rules and the proviso to Rule 17 were ultra vires Regulation 4(iii-a) of the IAS (Appointment by Competitive Examination) Regulations, 1955.

Analysis: The eligibility scheme under Regulation 4(iii-a) and Rule 4 was read harmoniously. The power to notify exceptions to the permitted attempts was held to include a valid operational restriction in specified circumstances. The proviso was treated as carving out an exception to the general rule, not as rewriting the substantive eligibility criteria. The restriction that a candidate already allocated and appointed to a service must resign before reappearing was viewed as a reasonable condition consistent with the recruitment framework and the purpose of preserving effective training and service discipline.

Conclusion: The proviso was held not to be ultra vires Regulation 4(iii-a), and the proviso to Rule 17 was also upheld.

Issue (ii): Whether the impugned proviso was arbitrary, unreasonable, or lacking nexus with the object of the recruitment scheme.

Analysis: The recruitment scheme was held to be aimed at securing the best candidates and ensuring that those selected devote themselves to probationary training. The Court accepted the governmental concern that probationers were neglecting training while preparing for a further examination. The restriction was therefore found to bear a dynamic and rational connection with the object of maintaining training discipline, service efficiency, and effective administration in the higher civil services.

Conclusion: The proviso was held neither arbitrary nor unreasonable, and it was found to have a rational nexus with the object sought to be achieved.

Issue (iii): Whether the proviso offended Articles 14, 16 and 335 of the Constitution of India by creating hostile discrimination, including as against candidates from Scheduled Castes and Scheduled Tribes and between Group 'A' and Group 'B' services.

Analysis: The Court held that IAS, IFS, IPS, Central Services Group 'A' and Group 'B' are distinct cadres with different status, prospects, pay scales, and conditions of service. The classification was found to rest on intelligible differentia and to have a rational relation to the object of the rules. The proviso applied uniformly to all within the affected category and did not single out candidates on constitutionally prohibited grounds. The special position of SC/ST candidates in matters of age relaxation and other concessions was recognised, but no separate exemption from the impugned proviso was found to exist.

Conclusion: The proviso was held not to violate Articles 14, 16 or 335 of the Constitution of India, and the discrimination challenge failed.

Final Conclusion: The challenge to the validity of the second proviso to Rule 4 of the Civil Services Examination Rules failed, the connected constitutional and statutory objections were rejected, and the appeals were dismissed, save for the limited directions already preserved for candidates covered by the earlier interim orders.

Ratio Decidendi: A service rule that imposes a limited and uniform restriction on already selected candidates to preserve training discipline and administrative efficiency is valid if it is a reasonable proviso to the main rule, has a rational nexus with the recruitment objective, and rests on an intelligible classification having no hostile discrimination.

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