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Issues: Whether the time prescribed for the District Inspector of Schools to approve or reject a panel under the relevant recruitment rules was mandatory or directory, and whether the Court could direct automatic approval of the panel without the statutory authority first examining its validity.
Analysis: The relevant rules required the District Inspector of Schools to pass an order on the panel within 30 days, but the prescription of time for performance of a statutory duty was held to be directory and not mandatory. The Court held that expiry of the period did not create automatic approval of the panel. It was further held that the Court could not substitute itself for the statutory authority by directing approval without allowing the authority to apply its mind to the legality and validity of the panel in the first instance.
Conclusion: The direction for automatic approval could not be sustained. The statutory authority was required to decide the panel's validity according to law before any approval could follow.
Final Conclusion: The appeal succeeded, the impugned approval direction was set aside, and the matter was sent back for fresh consideration by the competent authority in accordance with law.
Ratio Decidendi: A time-limit prescribed for performance of a statutory duty is directory unless the statute clearly makes it mandatory, and courts cannot compel approval by displacing the statutory authority's discretion.