Supreme Court Revives Excluded Candidates in TNPSC Motor Vehicle Inspector Recruitment Stalled Since 2018

A bench of Justices J.K. Maheshwari and Atul S. Chandurkar restores candidates excluded over workshop approval gaps, directing TNPSC to complete selection from a wider eligible pool.

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 nine sets of civil appeals arising from a Madras High Court Division Bench judgment dated 22 December 2023. The Court upheld the direction to redo the selection process so that candidates who were shut out because their workshops lacked timely renewal of approval could compete on equal terms. It also confirmed that candidates not in the zone of consideration are entitled to receive their individual marks, and that a certificate from the head of an institution is sufficient proof of Tamil-medium education for the Persons Studied in Tamil Medium quota.

How the Recruitment Unravelled

The TNPSC issued Notification No. 3/2018 on 14 February 2018 inviting applications for 113 posts. Selection was structured in three stages: a written examination, certificate verification, and an oral interview. Of 2,176 applicants, 1,328 cleared initial screening and sat the written test. Only 33 passed. One withdrew, leaving 32 candidates who received appointment orders on 4 November 2019.

Those 32 appointments did not survive. Writ petitions filed by excluded candidates led a Madras High Court Single Judge, by judgment dated 24 January 2020, to set aside the entire list. The judge directed fresh verification of workshop experience certificates for all 1,328 candidates and clarified that one year of experience meant at least 240 working days in a given year. A Division Bench of the High Court largely upheld those directions in writ appeals, and a challenge to that order before the Supreme Court was dismissed on 19 January 2021.

The TNPSC then published a revised list of 226 candidates on 28 April 2021, calling them for an oral test. Fresh writ petitions followed. A Single Judge, by order dated 10 February 2023, directed the TNPSC to complete the selection and publish a final list. Writ appeals against that order produced the impugned Division Bench judgment of 22 December 2023, which found that the approval renewal process for workshops had been handled arbitrarily and directed the entire recruitment to be redone.

The Workshop Approval Problem

The core dispute concerned candidates whose workshop experience certificates came from workshops that had held MVMD approval but whose renewal applications were pending or had been processed with retrospective effect. The Division Bench found that prior to 2012–13, the Director of the Motor Vehicles Maintenance Department had granted retrospective approval to workshops at his own discretion. No policy decision was placed on record to show that this practice was either authorised or discontinued after 2012–13. The Division Bench found that approach arbitrary and discriminatory.

The High Court also found that the workshops in question had continued to service Government vehicles even during the period when their renewal was pending, and that neither the candidates nor the workshops had any control over when renewal certificates would be issued. Depriving a candidate of the right to seek employment on account of a delay that was not of his making was, in the Division Bench's view, impermissible.

Acting on the Division Bench's direction in paragraph 88(a) of its judgment, the MVMD undertook a re-verification exercise. Before the Supreme Court stayed that direction on 17 May 2024, the MVMD had already submitted its re-verification report to the TNPSC on 10 April 2024. That report certified that 794 of the 1,328 candidates possessed one year of workshop experience once retrospective approval was factored in. The appellants in the first batch of appeals — candidates whose names had appeared in the original list of 33 but were excluded from the revised list of 226 — were confirmed by the MVMD's counter affidavit to each have more than one year of verified workshop experience.

What the Supreme Court Held on the Excluded Candidates

The Court accepted the MVMD's re-verification report without challenge. Since the retrospective renewal exercise had already been completed and the appellants in the first batch were confirmed to have the requisite experience, the Court held that their names must be considered for inclusion in the select list to be published by the TNPSC under paragraph 88(b) of the Division Bench judgment. The Court was clear, however, that these candidates would have to compete with all other eligible candidates; placement in the original list of 33 conferred no automatic right to selection.

For the second batch of appellants — candidates whose names were in the revised list of 226 and who objected to being made to go through the process again — the Court found no ground to interfere with the Division Bench's reasoning. The Court held that once a class of candidates had been deprived of proper participation in the selection process through no fault of their own, directing a fresh process was justified. The Court added that no vested right arises merely from placement in a select list when the right to participate in the fresh process is preserved. The direction to redo the recruitment, the Court said, “results in providing a level playing field to all the candidates.”

The Court expressly found the Division Bench's reasoning on the workshop renewal issue “cogent and in accordance with law.” It noted that candidates who gained experience in workshops shown as approved on the relevant website, or in workshops whose renewal applications were pending while they continued to service Government vehicles, could not be prejudiced by administrative delay.

PSTM Quota and Marks Disclosure

The TNPSC had challenged two further directions in its own appeals. The first concerned the Persons Studied in Tamil Medium quota. The TNPSC had argued that it could independently verify whether an institution used Tamil as its medium of instruction, beyond the certificate issued by the head of that institution. Both the Single Judge and the Division Bench had rejected that position, holding that a certificate from the head of the institution where a candidate completed a diploma course in Tamil medium was sufficient, particularly since Notification No. 3/2018 prescribed no additional requirement. The Supreme Court agreed, noting that the candidates had written their examinations in Tamil and that there was no basis to require further verification from the Directorate of Technical Education.

The second direction required the TNPSC to communicate individual marks to candidates who did not fall within the zone of consideration. The TNPSC relied on the Supreme Court's earlier decision in Joint Directors and Central Public Information Officer v. T.R. Rajesh (2018 INSC 179) to argue that such disclosure was impermissible. The Division Bench had read that decision differently: it held that where a court finds public interest requires disclosure, it may direct it. Given that the recruitment had been in litigation for more than five years and marks of some candidates had already been made public, the Division Bench directed individual communication of marks to all candidates, while clarifying that answer sheets would not be provided. The Supreme Court found no reason to take a different view, observing that all relevant aspects had been considered and public interest in disclosure was established.

Outcome

All nine sets of civil appeals were disposed of on 15 June 2026. The Court directed the TNPSC to complete the entire selection process at the earliest and in accordance with the time schedule set by the High Court. The candidates in the first batch whose workshop experience has been verified by the MVMD are to have their names considered for the select list under paragraph 88(b) of the Division Bench judgment, competing alongside all other eligible candidates. The directions on the PSTM quota and marks disclosure were affirmed. All pending interlocutory applications were disposed of. The judgment was authored by Justice Atul S. Chandurkar.