Krishnadatt Awasthy vs. State of Madhya Pradesh
Citation: 2025 INSC 126; Bench: Justice Hrishikesh Roy, Justice Sudhanshu Dhulia, Justice S.V.N. Bhatti
Background
The case arose from the selection and appointment of Shiksha Karmi Grade III teachers in Janpad Panchayat, Gaurihar, Chhatarpur District, Madhya Pradesh, dating back to 1998. Fourteen candidates, including Krishnadatt Awasthy and other appellants, were selected and subsequently appointed. It was later discovered that these individuals were close relatives of members of the selection committee, raising serious allegations of nepotism and bias in the process.
The selection was challenged by unsuccessful candidates, notably Archana Mishra, leading to the Collector’s order canceling the appointments on June 2, 1999. The appellants argued they were not given notice nor made parties to the proceedings that led to the annulment of their appointments, thereby violating their right to a fair hearing (audi alteram partem).
Key Legal Issues
Whether the cancellation of appointments due to bias (nemo judex in causa sua) can stand when the selected candidates were not given an opportunity to be heard (audi alteram partem).
Whether the principles of natural justice require impleadment and notice to affected candidates in service matters, especially where specific allegations are made.
Supreme Court’s Analysis
The case led to a split verdict in a two-judge bench, with one judge emphasizing the rule against bias and the other upholding the right to a fair hearing. The matter was referred to a three-judge bench for resolution.
The Supreme Court, in its final judgment, held that both limbs of natural justice—freedom from bias and the right to a fair hearing—are foundational and must be harmonized. The Court found that since the allegations of nepotism were specific, identifiable, and limited to 14 out of 249 selected candidates, it was both possible and necessary to give notice and an opportunity to be heard to those affected. The failure to do so amounted to a “gross violation” of natural justice.
The Court cited precedents such as J.S. Yadav v. State of Uttar Pradesh and Prabodh Verma v. State of Uttar Pradesh, reiterating that in service jurisprudence, selected candidates against whom specific allegations are made must be impleaded and heard, even if the overall number is large.
Decision
The Supreme Court allowed the appeals, set aside the Collector’s order canceling the appointments, and directed that the appellants be given a fair hearing before any adverse action is taken against them. The judgment reaffirmed that the right to a fair hearing cannot be sacrificed even in the face of proven bias, and that both principles of natural justice must be respected.
Significance
This decision is a landmark on the interplay between the rule against bias and the right to a fair hearing. It clarifies that in service matters, especially where specific allegations of nepotism or corruption are made, affected parties must be given notice and an opportunity to defend themselves before their appointments are annulled. The ruling strengthens procedural fairness and sets a precedent for future administrative and service law disputes.
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