Statutory recruitment rules control primary teacher appointments; unsuccessful candidates cannot claim parity or override the selection process.

Statutory recruitment rules governed primary teacher appointments under the West Bengal Primary Education Act, 1973 and the 1991 Rules, so trained but unsuccessful candidates had no enforceable right to appointment dehors the prescribed selection procedure. Earlier Supreme Court directions were held inapplicable because they arose from a different factual and statutory framework and could not displace the later rules. Article 14 also could not be invoked for parity with candidates not similarly situated. The stated principle is that courts cannot order appointments in breach of mandatory recruitment rules, and equality claims cannot bypass a materially different legal regime.

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Issues: (i) Whether the petitioners, being trained teachers but unsuccessful candidates, could claim appointment as Primary Teachers dehors the Recruitment and Leave Rules, 1991. (ii) Whether the earlier Supreme Court directions relating to recruitment in different factual and statutory circumstances entitled the petitioners to similar relief. (iii) Whether Article 14 could be invoked to obtain parity with candidates who were not similarly situated.

Issue (i): Whether the petitioners, being trained teachers but unsuccessful candidates, could claim appointment as Primary Teachers dehors the Recruitment and Leave Rules, 1991.

Analysis: The recruitment process was governed by the statutory regime framed under the West Bengal Primary Education Act, 1973. The rules required sponsorship of trained and untrained candidates by the Employment Exchange and prescribed a statutory procedure for selection and empanelment. The petitioners were not selected and had no independent legal right to automatic appointment merely because they had obtained junior basic training. Courts cannot direct appointments in violation of mandatory recruitment rules, and unsuccessful candidates cannot succeed absent pleaded and proved illegality in the selection process.

Conclusion: The claim to appointment dehors the statutory rules was rejected and is against the appellants.

Issue (ii): Whether the earlier Supreme Court directions relating to recruitment in different factual and statutory circumstances entitled the petitioners to similar relief.

Analysis: The earlier directions arose from a different recruitment process, under a different legal setting, and before the 1991 Rules came into force. Those directions could not override the later statutory framework, particularly where the relevant circulars and policy decisions had been displaced by the 1973 Act and the 1991 Rules. The precedent was therefore held to be inapplicable on facts and law.

Conclusion: The earlier Supreme Court directions did not assist the appellants and the plea for similar relief failed.

Issue (iii): Whether Article 14 could be invoked to obtain parity with candidates who were not similarly situated.

Analysis: Equality under Article 14 operates only among persons similarly situated. The appellants could not claim parity with candidates covered by a different recruitment regime or a different factual matrix. A judgment or direction rendered in one set of facts cannot be mechanically transplanted to another.

Conclusion: Article 14 afforded no relief to the appellants.

Final Conclusion: The operative statutory rules controlled the field, the appellants had no enforceable right to appointment, and the challenge to the refusal of relief was unsustainable.

Ratio Decidendi: Where statutory recruitment rules govern appointments, a court cannot direct appointment contrary to those mandatory provisions, and precedent or equality claims cannot be used to bypass a materially different statutory and factual context.

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