Merit and ability govern school promotions; interference is improper when appellate review ignores relevant material and relies on irrelevant factors.
Rule 15(4) requires promotion to Headmaster to be based on merit and ability, with seniority relevant only where candidates are approximately equal. The school committee's comparative assessment in favour of one candidate was displaced by the appellate authority and the High Court on considerations that were of limited or doubtful relevance, while material factors supporting the management's choice were ignored. On judicial review, interference is proper where the statutory authority relies on irrelevant considerations, omits relevant material, or acts in misdirection of law. The Supreme Court held that consent to re-examination did not authorise a decision contrary to the statutory scheme, and the impugned order and judgment were set aside with remand for fresh consideration.
Issues: Whether the appellate authority and the High Court were justified in interfering with the school management's selection of a Headmaster under Rule 15(4) by treating irrelevant factors as decisive and ignoring relevant considerations relating to merit and ability.
Analysis: Rule 15(4) requires promotion to be made on the basis of merit and ability, seniority operating only where the two candidates are approximately equal. The school committee had made a comparative assessment and selected the appellant, but the appellate authority substituted its own view by relying on considerations of limited or doubtful relevance, while overlooking material factors relied on by the management. In judicial review under Article 226, interference is warranted where the statutory authority acts on irrelevant considerations, ignores relevant material, or commits misdirection in law. Consent to a re-examination of the matter did not confer jurisdiction to decide contrary to the statutory scheme, nor could it prevent the appellant from challenging an order suffering from jurisdictional error.
Conclusion: The interference with the school committee's decision was unsustainable, and the appellant's challenge succeeded.
Final Conclusion: The appellate authority's order and the High Court's judgment were set aside, and the matter was remitted for fresh consideration in accordance with law.
Ratio Decidendi: A statutory appellate authority exercising review over a school management's selection must act within the governing rule, and its decision is liable to be set aside if it is founded on irrelevant considerations, ignores relevant material, or suffers from misdirection in law.
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