Extra eligibility filters in service selection are impermissible when they exclude otherwise qualified officers from consideration.

Where recruitment regulations prescribe the eligibility criteria for selection to the Indian Administrative Service, the administration cannot add a further disqualifying condition based only on seniority or departmental hierarchy. Eligible officers who satisfy the prescribed merit, service, status and age requirements must be considered under the governing rules, and exclusion by an extra-statutory restriction creates unequal treatment among similarly situated candidates. The restriction of the zone of consideration was therefore unlawful, and exclusion on that basis was inconsistent with the guarantee of equality and equal opportunity in public employment.

---

---

Issues: Whether eligible officers could be excluded from consideration for selection to the Indian Administrative Service by restricting the zone of consideration to officers of a higher level than that prescribed by the governing regulations, and whether such exclusion violated equality in public employment.

Analysis: The Regulations required the State Government to propose eligible persons who satisfied the prescribed criteria, including outstanding merit and ability, substantive gazetted status, the requisite length of service, and the prescribed age limit. The governing framework did not authorise an additional restriction based merely on seniority or departmental hierarchy once candidates otherwise satisfied the eligibility conditions. The introduction of such a restriction amounted to adding a criterion not found in the rules, resulting in dissimilar treatment of similarly situated officers. The exclusion of otherwise eligible candidates on that basis was therefore inconsistent with the guarantee of equality and equal opportunity.

Conclusion: The restriction of the zone of consideration was unlawful, and the appellant was entitled to be considered along with other eligible officers. The exclusion was held to be contrary to the equality guarantee.

Ratio Decidendi: Where a recruitment or selection rule prescribes the eligibility criteria, the administration cannot superimpose an additional disqualifying criterion not found in the rules, and exclusion of otherwise eligible persons on that basis violates equality in public employment.

---