Source: Rajasthan High Court 

Why in News? 

In the matter of Kiran Yadav v. The State of Rajasthan & Ors., the Rajasthan High Court has restated that the hallmark of judicial pronouncements is its stability and finality and thus, they should not be unsettled lightly. 

What was the Background of Kiran Yadav v. The State of Rajasthan & Ors. (2025) Case? 

Background and Initial Proceedings: 

• Kiran Yadav, aged 28 years, resident of Bijli Ghar Ke Pass, Singod Khurd, Viya Khejruli, District Jaipur, filed a writ petition challenging the cancellation of her appointment as Physical Training Instructor (PTI). 
• The case originated from an advertisement dated 16th June 2022 for the post of PTI, where petitioner participated in the selection process. 
• Required qualification as per Clause 7 of the advertisement: Senior Secondary or equivalent examination from recognized Board plus Certificate/Diploma/bachelor's in physical education recognized by Government/National Council for Teacher Education. 

Educational Qualification Timeline: 

• The advertisement specified that candidates appearing in the qualifying examination could participate, subject to possessing requisite qualifications on or before the date of written examination. 
• Petitioner's B.P.Ed. result was first declared on 19th September 2022 - she was declared "FAIL" in one paper. 
• The written examination for PTI post was conducted on 25th September 2022. 
• The petitioner applied for re-evaluation of her answer sheet. 
• Re-evaluation result was declared on 23rd November 2022, wherein petitioner was declared "PASS". 

Appointment and Cancellation Journey: 

• Based on merit secured and treating her as eligible, petitioner was offered appointment on 15th December 2022. 
• Petitioner joined her duties as PTI pursuant to an appointment order dated 15th December 2023. 
• After joining, respondents cancelled her appointment vide impugned order dated 16th January 2025. 
• The cancellation was based on technical grounds that she did not possess the requisite educational qualification on the date of written examination. 

Before High Court: 

• Petitioner challenged the cancellation order dated 16th January 2025 by filing S.B. Civil Writ Petition No. 1628/2025 before High Court of Judicature for Rajasthan, Bench at Jaipur. 
• The case was heard by Justice Anoop Kumar Dhand. 
• An order was reserved.

What were the Court’s Observations? 

Precedent Analysis and Legal Position: 

• The court relied on the Supreme Court judgment in Jenany J.R. v. S. Rajeevan & Ors. (2010), which held that re-evaluation results cannot relate back to original result date. 

Court's Reasoning on "Relate Back" Theory: 

• The court rejected the "relate back" theory, stating that if re-evaluation results could relate back, it would create a dangerous precedent. 
• Hypothetical scenario considered: If re-evaluation result is declared after six months when the entire selection process is over, the entire process cannot be conducted individually for one candidate. 
• The court emphasized that person's candidature must be examined only on the cut-off date. 
• Law must meet all contingencies and circumstances. 

Final Judgment: 

• The court found no merit in the writ petition and rejected it. 
• Cancellation of petitioner's appointment was upheld as legally justified. 
• All pending applications, including stay applications, were dismissed. 

What are the General Principles of Judicial Pronouncements & Verdicts? 

Constitutional Mandate and Binding Nature:  

• Article 141 of Constitution of India, 1950 (COI) states that law declared by Supreme Court is binding on all courts within territory of India. 
• This ensures consistency and uniformity in application of law across the country. 
• Courts cannot depart from established precedents unless there are compelling reasons.  

Doctrine of Stare Decisis: 

• Stare decisis is a well-settled valuable principle of precedent that cannot be departed from lightly. 
• In a country governed by the Rule of Law, the finality of judgment is absolutely imperative. 
• Parties cannot re-open concluded judgments of the Court. 
• Judgments of the Court, particularly of the Supreme Court, cannot and should not be unsettled lightly. 

Characteristics of Judicial Verdicts: 

• Hallmark of judicial pronouncement is its stability and finality. 
• Judicial verdicts are not like sand dunes which are subject to vagaries of wind and weather. 
• Judicial pronouncements must have permanence and cannot be subject to constant change. 

Abuse of Process: 

• Re-opening concluded judgments would be tantamount to abuse of process of law and Court. 
• Such practice would have far reaching adverse effects on administration of justice. 
• Courts must maintain sanctity of judicial process and prevent misuse of legal procedures. 

Rule of Law Principles: 

• Courts must follow established legal principles and cannot create exceptions without valid justification. 
• The legal system requires predictability and consistency in judicial decisions. 
• Precedents serve as foundation for legal certainty and public confidence in the judicial system.