Vashist Narayan Kumar vs. State of Bihar
Citation: 2024 INSC 2; Bench: Justice K.V. Viswanathan, Justice J.K. Maheshwari
Background
Vashist Narayan Kumar, from a small village in Bihar and belonging to a marginalized community, applied for the post of Police Constable under the reserved category. He fulfilled all eligibility criteria, cleared the written examination and the Physical Eligibility Test, and submitted his educational and caste certificates for verification. However, his final result was marked as “failed” solely because his date of birth was entered as 08.12.1997 in the online application, while his school mark sheet reflected 18.12.1997 as his correct birth date.
Distressed by the rejection, Kumar filed a representation and, upon receiving no response, approached the Patna High Court. Both the Single Judge and Division Bench of the High Court denied relief, holding that the error constituted incorrect information justifying his disqualification.
Supreme Court’s Analysis
Nature of the Error:
The Supreme Court examined whether the discrepancy in the date of birth was a material misrepresentation or a trivial, inadvertent mistake. The Court found that the error was minor and unintentional, arising from the process of online form submission at a cyber café, and did not amount to deliberate suppression or misleading information.
Principle of De Minimis:
Applying the legal maxim de minimis non curat lex (the law does not concern itself with trifles), the Court held that such trivial errors should not form the basis for rejecting a candidate who had otherwise cleared all stages of the selection process. The error had no bearing on the appellant’s eligibility or the outcome of the selection.
Power to Mould Relief:
The Court observed that writ courts have the authority to mould relief to ensure justice is not sacrificed on technicalities. The prayer in the writ petition was sufficient to seek reconsideration of the appellant’s candidature based on the correct date of birth.
State’s Conduct:
The Court criticized the State for making “a mountain out of a molehill” and for not considering the appellant’s background or the circumstances under which the error occurred.
Decision
The Supreme Court set aside the cancellation of Kumar’s candidature, directed the State to treat his date of birth as 18.12.1997, and to issue an appointment letter if he was otherwise eligible. The Court reaffirmed that inadvertent clerical errors do not amount to misrepresentation or suppression of facts and should not deprive deserving candidates of public employment.
Significance
This judgment is a significant affirmation of the principle that minor, unintentional errors in public service applications should not defeat substantive justice. It underscores the judiciary’s commitment to fairness, especially for candidates from disadvantaged backgrounds, and discourages hyper-technical disqualification by authorities.
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