Supreme Court Upholds Fresh TNPSC Recruitment Exercise for Motor Vehicle Inspector Posts, Restores Excluded Candidates

A Division Bench of the Supreme Court upheld a direction to redo the TNPSC Motor Vehicle Inspector selection, ruling no vested right arises from placement in an intermediate select list.

A recruitment drive for 113 posts of Motor Vehicle Inspector — Grade II in the Tamil Nadu Transport Subordinate Services, launched by the Tamil Nadu Public Service Commission in February 2018, has spent more than six years in litigation. On 15 June 2026, the Supreme Court disposed of a clutch of civil appeals arising from a Madras High Court judgment that had directed the entire selection process to be restarted. The Court upheld that direction, restored candidates whose names had been dropped from an intermediate list after a re-verification of workshop experience certificates showed they met the eligibility criteria, and declined to interfere with directions requiring disclosure of marks to candidates outside the zone of consideration.

How the Dispute Reached the Supreme Court

The TNPSC issued Notification No. 3/2018 on 14 February 2018 inviting applications for 113 Motor Vehicle Inspector — Grade II posts. Selection was to proceed in three stages: a written examination, certificate verification, and an oral interview. Of 2,176 applicants, 1,328 were permitted to sit the written examination. Only 33 passed. One withdrew, leaving 32 candidates who received appointment orders on 4 November 2019.

Those 32 appointments were challenged before the Madras High Court. A Single Judge set them aside on 24 January 2020, directed fresh verification of workshop experience certificates for all 1,328 candidates, and clarified that one year of experience would be satisfied by at least 240 working days in a given year. A Division Bench of the High Court partly allowed the writ appeals that followed, directing a 1:2 ratio list to be drawn before oral tests. That order was challenged before the Supreme Court in K. Ilavarasan and others v. R. Vijiyaraj and others, but those proceedings were dismissed on 19 January 2021.

The TNPSC then published a revised list of 226 candidates on 28 April 2021 and called them for oral test. Candidates excluded from that list filed fresh writ petitions. A Single Judge decided those petitions on 10 February 2023, dividing the issues into eleven batches, and directed the TNPSC to complete the selection and publish a final list. Writ appeals followed. The Division Bench, by its common judgment dated 22 December 2023, found that there was no uniform policy governing retrospective renewal of workshop approvals, that the Director had been granting such renewals at his own discretion, and that this was arbitrary. It directed the entire recruitment process to be redone after the Transport Department took a conscious decision on retrospective renewal of workshop approvals. That judgment is what the Supreme Court was asked to examine.

Three Sets of Appellants, Three Distinct Grievances

The appeals before the Supreme Court fell into three groups.

The first group comprised candidates — including S. Senthil Kumaran Bose, N. Vaithi and others, and M. Mohammed Adhil — whose names had appeared in the original list of 33 candidates published on 15 July 2019 but were absent from the revised list of 226 candidates published on 28 April 2021. Their grievance was that the High Court's direction to re-verify workshop experience should have resulted in their inclusion in the selection process.

The second group — including S. Dinesh Kumar, G. Ramkumar, P. Karthic and others, J. Saranya and others, and U. Omezhilan and others — were candidates whose names were in the 226-candidate list of 28 April 2021. They objected to being made to undergo the entire selection process again.

The third appellant was the TNPSC itself, aggrieved by the direction to disclose marks to candidates who did not fall within the zone of consideration.

Re-Verification Resolves the First Group's Claims

The Motor Vehicles Maintenance Department of Tamil Nadu filed a counter affidavit dated 9 January 2025 before the Supreme Court. It stated that, pursuant to the Division Bench's direction in paragraph 88(a) of the impugned judgment, retrospective approval had been granted to all approved workshops and the MVMD had submitted re-verified workshop experience reports for all 1,328 candidates to the TNPSC on 10 April 2024.

The re-verification showed that each of the appellants in the first group now had more than one year of workshop experience in an approved workshop. A consolidated chart placed before the Court confirmed this for each candidate individually. The Court noted that this re-verification report had not been challenged by any party.

The Court held that since the MVMD had duly verified and re-verified the workshop experience certificates and confirmed that each appellant's experience exceeded one year, those appellants were entitled to have their names considered for inclusion in the select list to be published by the TNPSC under paragraph 88(b) of the High Court's directions. They would, however, have to compete with all other eligible candidates. The civil appeals in this group were disposed of accordingly.

No Vested Right in an Intermediate Select List

The second group of appellants argued that the High Court had no justification in setting aside the steps taken up to the date of its judgment and directing the entire process afresh. They relied on several Supreme Court decisions, including Ashok Kumar Yadav and others v. State of Haryana and others (1985 INSC 137), U.P. Public Service Commission v. Subhash Chandra Dixit and others (2003 INSC 606), Sunil Kumar and others v. Bihar Public Service Commission and others (2015 INSC 770), and State of Uttar Pradesh and others v. Atul Kumar Dwivedi and others (2022 INSC 24).

The Court found the Division Bench's reasoning cogent. The workshops that had issued experience certificates were shown to be approved on the concerned website, and even during periods when renewal applications were pending, those workshops had been attending to Government vehicles. Neither the candidates nor the workshops had any control over when renewal certificates would be issued. The Director had been granting retrospective approvals at his own discretion without any policy basis, which the Division Bench found arbitrary and discriminatory.

The Court agreed that a direction to take a conscious policy decision on retrospective renewal — and then to redo the selection on that basis — was aimed at providing a level playing field. It would also result in a larger pool of meritorious candidates, which the Court said was in public interest.

On the question of vested rights, the Court was direct: “No vested right could be claimed merely by placement in the revised select list.” The right to participate in the fresh selection process was not being taken away from those in the 226-candidate list. The Court found no justifiable legal ground to interfere with the Division Bench's direction to redo the recruitment. Those civil appeals were also disposed of.

PSTM Quota and Marks Disclosure

The TNPSC raised two further objections. First, it contested the finding that a certificate from the Head of the Institution where a candidate had studied in Tamil medium was sufficient for the Persons Studied in Tamil Medium quota. The TNPSC had argued it could independently verify whether an institution used Tamil as its medium of instruction, and that the Directorate of Technical Education should also be involved. The Single Judge had rejected this, holding that the Head of Institution's certificate was sufficient, particularly since Notification No. 3/2018 prescribed no additional requirement. The Division Bench upheld that finding. The Supreme Court agreed with both courts.

Second, the TNPSC challenged the direction in paragraph 88(f) of the High Court's judgment requiring it to communicate marks individually to candidates who did not fall within the zone of consideration. The TNPSC relied on the Supreme Court's own decision in Joint Directors and Central Public Information Officer and another v. T.R. Rajesh (2018 INSC 179). The Division Bench had relied on the same decision to hold that where a court finds public interest requires disclosure, it may issue such a direction. It had also noted that marks of some candidates had already been made public, and that the recruitment had been in litigation for more than five years. The direction was limited: candidates would not receive copies of their answer sheets, only their marks.

The Supreme Court found no reason to take a different view. All relevant aspects had been considered and the Court was satisfied that public interest required the disclosure.

Outcome

All three sets of civil appeals were disposed of. Candidates from the first group — whose names had been in the original list of 33 but were excluded from the 226-candidate list — are entitled to have their names considered for the select list to be published under paragraph 88(b) of the High Court's directions, subject to competing with all other eligible candidates. The direction to redo the entire recruitment process was upheld. The TNPSC was directed to complete the entire exercise at the earliest and in accordance with the time schedule stipulated by the High Court. The directions on the PSTM quota and marks disclosure were also upheld. All pending interlocutory applications were disposed of.