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Issues: Whether the communal rotation under Rules 14 to 17 of the Kerala State & Subordinate Services Rules, 1958 had to be worked out with each block of 20 vacancies as the unit of appointment, or whether vacancies reported in excess of 20 could be treated as one unit so as to apply reservation by reference to the total vacancies in a requisition.
Analysis: Rule 14(a) fixes the unit of appointment as 20 and specifies the division between open competition, reserved categories and merit-based selection. Rule 14(b) permits meritorious reserved-category candidates to be adjusted against open competition turns, but only within the framework of the unit of 20. Rules 14(c), 15(a), 16 and 17 operate the rotation, sub-rotation and integrated cycle for reservation, but they do not alter the statutory unit of appointment. The interpretation adopted by the High Court was held to amount to reading an additional proviso into Rule 14(a), which would make the unit depend on the number of vacancies reported and would impermissibly rewrite the rule. The accepted practice of applying reservation on a 20-point basis was treated as consistent with the Rules, and the literal meaning of the provisions was preferred over a purposive reading that would produce hardship or perceived administrative convenience.
Conclusion: The correct construction is that reservation and rotation are to be applied to each batch of 20 candidates as a separate unit, and not to the entire notified vacancies as one unit. The High Court's contrary view was rejected and the appeals succeeded.