Purposive reading of women's age relaxation rules preserved eligibility for police recruitment despite no express clause in earlier rules.

Women candidates were entitled to the ten-year age relaxation under the special women's rules read with the State Services Examination Rules, because those rules preserved the benefit for the examination and had to be interpreted purposively to advance women's participation in public employment. The recruitment was governed by the 2000 rules applicable to the vacancy year, but those rules did not exhaust age-relaxation policy. The later express women's relaxation clause in the 2005 rules reinforced that the omission in the earlier rules was not intended to withdraw the benefit. The candidate was therefore eligible for consideration for appointment as Deputy Superintendent of Police.

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Issues: Whether the appellant, a woman candidate, was entitled to the age relaxation of ten years for the post of Deputy Superintendent of Police under the special women's rules and the State Services Examination Rules, notwithstanding the age bar in the police recruitment rules.

Analysis: The recruitment process was initiated against vacancies that arose when the 2000 recruitment rules were in force, so the process was validly conducted under those rules and not under the 2005 rules. However, the 2000 rules did not exhaust the field on age relaxation. The women's special rules framed under Article 309 of the Constitution of India granted a ten-year relaxation to women candidates for public service posts, and the State Services Examination Rules, 2003 specifically carried that benefit forward for the examination in question. The interpretive approach adopted was purposive, giving effect to the statutory object of encouraging women's participation in public employment and avoiding a construction that would defeat that object. The later insertion of an express women's relaxation clause in the 2005 rules also confirmed that the omission in the 2000 rules was not meant to deny the benefit.

Conclusion: The appellant was entitled to the age relaxation available to women candidates and was eligible for consideration for appointment as Deputy Superintendent of Police.

Ratio Decidendi: A special rule conferring age relaxation on women candidates for public service must be given purposive effect and read with the governing examination rules, so that the benefit is not denied merely because the recruitment rules contain no express women-specific relaxation clause.

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