Expert selection committee assessment upheld where no mala fides, quorum defect, or arbitrariness was shown.

Selection to the Indian Administrative Service was not vitiated by mala fides, as the alleged link between a residential allotment and the committee process was remote and unsupported by direct or indirect material. The Selection Committee was validly constituted because the governing regulations permitted proceedings to continue despite the absence of a non-essential member, and six of seven members attended, satisfying quorum with no shown prejudice. The evaluation of service records and interview marks was not arbitrary, since courts do not sit in appeal over a duly constituted expert body's assessment absent mala fides, patent illegality, or breach of rules. Judicial interference was therefore unwarranted and the selection was upheld.

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Issues: (i) Whether the selection to the Indian Administrative Service was vitiated by mala fides; (ii) Whether the Selection Committee was improperly constituted because one member was absent; (iii) Whether the evaluation of service records and interview marks was arbitrary or otherwise liable to be interfered with.

Issue (i): Whether the selection to the Indian Administrative Service was vitiated by mala fides.

Analysis: Allegations of mala fides were examined against the background of the allotment of a residential site to the Chairman of the Selection Committee and the supposed influence of State . The connection between the allotment and the later selection process was found to be remote and unsupported by direct or indirect material. The selection process was conducted by a multi-member committee and no basis was shown to attribute favouritism or personal bias to the process.

Conclusion: The allegation of mala fides failed and the selection was not vitiated on that ground.

Issue (ii): Whether the Selection Committee was improperly constituted because one member was absent.

Analysis: The governing regulations expressly provide that absence of a member other than the Chairman or Member of the Commission does not invalidate the proceedings if more than half the members attend. The post of Divisional Commissioner had been abolished, six of seven members participated, and the quorum requirement stood satisfied. No prejudice to the challengers was shown.

Conclusion: The Selection Committee was properly constituted and its proceedings were valid.

Issue (iii): Whether the evaluation of service records and interview marks was arbitrary or otherwise liable to be interfered with.

Analysis: The Court reiterated that recommendations of a duly constituted expert selection body are not to be reappraised as if in appeal. The Committee was entitled to assess the overall service record, seek special reports where annual reports were not timely available, and grade officers on its own assessment even if that differed from the reporting or reviewing officers. In the absence of mala fides, patent illegality, or violation of statutory rules, the Tribunal and the Court were not to substitute their own evaluation for that of the expert body.

Conclusion: The assessment and marking process was not arbitrary and did not warrant judicial interference.

Final Conclusion: The appeals challenging the High Court's reversal of the Tribunal's order were without merit, and the selection process was upheld in law.

Ratio Decidendi: Courts do not sit in appeal over the assessment of a duly constituted expert selection committee; interference is justified only for mala fides, patent illegality, or breach of the governing regulations, and quorum-compliant proceedings are not invalidated by the absence of a non-essential member.

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