In a significant verdict emphasizing fair calculation of academic eligibility and principles of natural justice, the Supreme Court of India has set aside the termination of three teachers from Jharkhand, ruling that marks from vocational subjects must be included when determining minimum qualifying percentages for recruitment. The judgment, delivered on October 9, 2025, overturns the Jharkhand High Court’s Division Bench decisions and reinstates appellants Ravi Oraon and Premlal Hembrom with full back wages and service continuity. For the deceased appellant Surendra Munda, heirs are entitled to arrears, with potential compassionate benefits. The court criticized the state’s arbitrary exclusion of vocational marks and violation of due process, highlighting that such actions undermine equity in public employment.
The case originated from a 2015 recruitment drive for Intermediate Trained Teachers (Classes I-V) in Dhanbad district, advertised under the Jharkhand Primary School Teacher Appointment Rules, 2012. The appellants, all from the Scheduled Tribe (ST) category, were selected and joined in December 2015. However, in September 2016, show-cause notices alleged they failed to meet the 45% intermediate mark requirement (relaxed to 40% for ST). Their graduation certificates from Hindi Vidyapeeth, Deoghar, were also questioned.
Responding, the appellants claimed entitlement to the 40% threshold and clarified graduation was not mandatory. Yet, on October 7, 2016, their services were terminated, recalculating marks excluding vocational subjects, yielding below 40%. Challenging this, the High Court’s Single Judge quashed the terminations in 2018 and 2022, but the Division Bench reversed in 2021 and 2022, upholding exclusions under Rule 21.
The Supreme Court, in a bench comprising Justices Dipankar Datta and K.V. Viswanathan, dissected the rules. It held Rule 4 governs eligibility for the Teacher Eligibility Test (TET), requiring 40% for ST without excluding vocational marks. Rule 21, under a separate chapter, applies only to merit list preparation post-TET, not initial eligibility. The court affirmed the marksheet guideline allowing bonus vocational marks (above pass level) to boost aggregates, enabling the appellants to exceed 40%.
Critically, the bench found a natural justice breach: terminations on unalleged grounds (vocational exclusion) without fresh notices violated due process. Citing Escorts Farms Ltd. (2004), it noted this was no “idle formality” but a substantive error.
Post-litigation developments were noted: Vidyapeeth degrees pre-February 26, 2015, were validated in 2022, and Ravi/Premlal were reappointed in January 2025 without past benefits. The SC granted continuity from 2015, full arrears within three months, but excluded non-duty periods for promotion experience. For Surendra (deceased August 5, 2024), heirs receive arrears and may seek compassionate appointment.
This ruling reinforces inclusive eligibility assessments, protects against procedural arbitrariness, and may impact similar recruitments nationwide, promoting vocational education’s value in public jobs.
Case Details:
- Case Title: Ravi Oraon vs. The State of Jharkhand & Ors. (and connected matters)
- Citation: 2025 INSC 1212
- Court: Supreme Court of India (Civil Appellate Jurisdiction)
- Appeal Numbers: Civil Appeal No. 11748 of 2025 (lead); Civil Appeal Nos. 11749 & 11750 of 2025
- Judges: Justice Dipankar Datta and Justice K.V. Viswanathan
- Date of Judgment: October 9, 2025
- Key Issue: Inclusion of vocational marks in intermediate eligibility for teacher recruitment; natural justice in terminations.
- Outcome: Appeals allowed; terminations quashed; reinstatement with back wages and continuity for survivors; arrears for deceased’s heirs.
Click HERE for full Judgment
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