Rational short-listing for interview may exceed minimum eligibility without changing statutory appointment criteria.

A rational short-listing criterion for interview was permissible where applications far exceeded vacancies and selection was by interview alone. The statutory minimum eligibility for appointment remained five years' practice under the Madhya Pradesh Industrial Relations Act, 1960, and the Commission did not alter that requirement by calling only candidates with seven and a half years' practice. The higher threshold was treated as part of the selection process to manage the interview pool, provided it had a nexus with the objective of identifying the best candidates and was not arbitrary. The short-listing method was upheld and the contrary view was set aside.

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Issues: Whether, in short-listing candidates for interview, the Commission could require more than the statutory minimum practice of five years prescribed for eligibility to the post of Presiding Officer of Labour Court, without altering the statutory criteria.

Analysis: Section 8(3)(c) of the Madhya Pradesh Industrial Relations Act, 1960 prescribed the minimum eligibility for appointment, namely five years' practice as an advocate or pleader. The Court held that fixing a higher threshold only for the purpose of limiting the number of candidates called for interview was part of the selection process and not a substitution of the statutory eligibility condition. Where applications are far in excess of vacancies and selection is by interview alone, the Commission may adopt a rational and objective short-listing method to facilitate proper assessment of merit. Such a method must have a nexus with the object of selecting the best candidates and cannot be arbitrary.

Conclusion: The Commission was entitled to short-list candidates for interview on a rational basis and its decision to call only those with seven and a half years' practice did not violate the statutory eligibility requirement.

Final Conclusion: The High Court's view was set aside and the Commission's short-listing method was upheld as a valid part of the selection process.

Ratio Decidendi: A rational short-listing criterion adopted to manage interviews for a large pool of eligible candidates is permissible if it does not change the statutory eligibility prescribed for appointment.

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