Recruitment rule interpretation upheld where one reasonable selection method was consistently applied and appointments were left undisturbed.

Rule 16 of the Recruitment Rules had to be read with Rule 17 as a workable scheme: the proviso on assessing suitability by total marks in the written examination applied to both the general qualifying-mark clause and the Scheduled Castes and Scheduled Tribes dispensation, not to the latter alone. For the 6th Combined Civil Services Examination, the Court accepted the Commission's construction that Paper-I of the main examination was qualifying and that merit was to be assessed on the remaining written examination scheme. Where the rules and advertisement admitted two reasonable interpretations and the selection process had consistently proceeded on one of them, judicial review should not unsettle appointments already made and acted upon. The appeals succeeded and the selection was left undisturbed.

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Issues: (i) Whether, under Rule 16 of the Recruitment Rules, the proviso governing assessment of suitability was confined only to the Scheduled Castes and Scheduled Tribes clause or applied to both clauses governing qualifying marks in the written examination; (ii) Whether, in the 6th Combined Civil Services Examination, the marks obtained in Paper-I of the main examination were to be added to the total merit or Paper-I was only qualifying and merit was to be prepared on the basis of the remaining papers.

Issue (i): Whether, under Rule 16 of the Recruitment Rules, the proviso governing assessment of suitability was confined only to the Scheduled Castes and Scheduled Tribes clause or applied to both clauses governing qualifying marks in the written examination?

Analysis: Rule 16 had to be read as a whole, along with Rule 17, to make the scheme workable. Clause (a) dealt generally with qualifying marks in the written examination, while clause (b) provided a special dispensation for Scheduled Castes and Scheduled Tribes. The proviso, which directs that suitability is to be judged on total marks in the written examination and not on marks in any particular subject, governs the stage of selection after qualification and is not confined to clause (b) alone. Punctuation could not override the clear scheme of the rules.

Conclusion: The proviso to Rule 16 applies to both clauses (a) and (b), not to clause (b) alone.

Issue (ii): Whether, in the 6th Combined Civil Services Examination, the marks obtained in Paper-I of the main examination were to be added to the total merit or Paper-I was only qualifying and merit was to be prepared on the basis of the remaining papers?

Analysis: The advertisement and Rule 16 together created ambiguity on whether merit in the main examination was to be determined on aggregate marks or by minimum qualifying marks in each paper. Both constructions were possible. In such a situation, the Court gave weight to the interpretation adopted by the Commission and the settled selection process already acted upon, particularly when appointments had been made and probation completed. The Court also distinguished the earlier decision relating to the preliminary examination and held that it could not control the present question concerning the main examination.

Conclusion: The Commission's interpretation that Paper-I was qualifying and that merit was to be assessed on the written examination scheme as applied in the selection process was accepted.

Final Conclusion: The appeals succeeded and the High Court's judgment was set aside, leaving the selection made under the 6th Combined Civil Services Examination undisturbed.

Ratio Decidendi: Where the governing recruitment rules and advertisement admit of more than one reasonable construction, and one such construction has been consistently acted upon in the selection process, judicial review should not unsettle the selection after appointments have been made and candidates have completed probation.

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