Residence-based recruitment preferences were struck down for lacking constitutional support and rational nexus, with prospective relief preserving completed appointments.

Residence-based bonus marks for public employment as primary school teachers were held unconstitutional because residence in a district or rural area, by itself, could not justify a preference in State service without constitutional or parliamentary authorisation. The policy also lacked a demonstrated rational nexus with the stated aims of improving primary education, rural uplift, local dialect accommodation, and teacher retention, and it was vague in fixing criteria for rural residence. The invalidity was applied prospectively to protect appointments already made under the earlier view, with relief confined to the petitioners and later appointments or pending selections after the cut-off date.

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Issues: (i) Whether bonus marks granted to candidates on the basis of residence in a particular district and its rural areas for public employment as primary school teachers were constitutionally valid. (ii) Whether the declaration of invalidity should operate prospectively so as to protect appointments already made and limit relief to the writ petitioners.

Issue (i): Whether bonus marks granted to candidates on the basis of residence in a particular district and its rural areas for public employment as primary school teachers were constitutionally valid.

Analysis: The preferential marks were examined against the guarantees of equality of opportunity and non-discrimination in public employment. Residence, by itself, could not be used as a basis for preference in State service unless saved by a valid constitutional or parliamentary exception. The circular neither disclosed any scientifically supported classification nor established a rational nexus between district residence or rural residence and the object of improving primary education. The asserted grounds of rural uplift, local dialect, and teacher retention were found unsupported by material and insufficient to justify a residence-based advantage. The circular also suffered from vagueness because it laid down no clear criteria for identifying a rural resident.

Conclusion: The bonus-mark scheme based on district and rural residence was unconstitutional and invalid.

Issue (ii): Whether the declaration of invalidity should operate prospectively so as to protect appointments already made and limit relief to the writ petitioners.

Analysis: The Court balanced the need to correct an unconstitutional policy against the practical consequences of unsettled selections already acted upon under then-prevailing judicial decisions. Considering the long-standing operation of the earlier view, the stage at which the challenge succeeded, and the need to avoid disturbing completed appointments, the Court invoked prospective application as a matter of relief. Relief was therefore confined to the petitioners before the Court and to appointments made on or after the cut-off date fixed by the judgment.

Conclusion: The invalidity of the circular was applied prospectively, earlier appointments were protected, and only later appointments and pending selections were subject to reconsideration in relation to the writ petitioners.

Final Conclusion: The residence-based bonus-mark policy in teacher recruitment was struck down, but the operative relief was tailored prospectively to prevent reopening appointments already made before the specified cut-off date.

Ratio Decidendi: In public employment, a preference founded solely on residence in a district or rural area is impermissible unless constitutionally authorised and supported by a demonstrable rational nexus with the object sought to be achieved; where the law is declared invalid after selections have been made under a then-prevailing view, the Court may confine the effect prospectively to do justice and avoid unsettling completed appointments.

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