In a landmark judgment delivered on January 15, 2026 (2026 INSC 64), the Supreme Court of India, in a bench led by Justice Dipankar Datta, allowed three connected civil appeals filed by the Rajasthan Public Service Commission (RPSC), Ajmer. The appeals challenged similar judgments of the Rajasthan High Court (Division Bench at Jaipur) that had upheld Single Judge orders directing consideration or appointment of candidates from reserve/waiting lists for posts of Junior Legal Officer (JLO) and Assistant Statistical Officer (ASO).
The cases involved three respondents: Yati Jain (SLP (C) No. 20366/2024), Aakriti Saxena (SLP (C) No. 20367/2024), and Vivek Kumar Meena (SLP (C) No. 22025/2024). These candidates sought appointments after selected candidates from the main merit list failed to join, relying on their positions in reserve lists prepared after recruitment advertisements issued between 2013 and 2020.
Key Facts from the Recruitments
For JLO (advertisement 19-09-2019): 156 posts advertised, results declared April 15, 2021. 152 candidates recommended; 6 vacancies arose due to non-joining. RPSC recommended 6 from reserve list (up to R-4, plus others), skipping Yati Jain (R-5). Later, one non-joiner’s appointment was cancelled, but no further requisition came, and a new advertisement for 140 JLO posts was issued in July 2023.
For ASO (advertisement 06-07-2020): 11 posts, 10 recommended, one (Sunil Machhera) declined to join for ISS. Aakriti Saxena (R-1 in reserve) applied, but no requisition followed.
For older JLO (2013-14): Similar pattern with non-joining of Raj Kumar Meena; Vivek Kumar Meena sought consideration.
The Rajasthan High Court Single Judges directed RPSC/authorities to pick names from reserve lists, citing timely writ petitions (within 6 months of non-joining) and precedents like Manoj Manu v. Union of India and others. The Division Bench dismissed RPSC’s writ appeals, noting the State Government had not appealed the Single Judge orders.
Supreme Court’s Key Rulings
The apex court clarified that reserve/waiting lists do not confer a vested or automatic right to appointment. Such lists are temporary mechanisms to fill unanticipated vacancies within a strict statutory timeframe (often 6 months from the date of forwarding the original list, per Rajasthan rules).
Justice Datta emphasized:
- No appointment possible without formal requisition from the appointing authority.
- Reserve lists expire after the prescribed period; candidates cannot claim indefinite rights.
- High Court erred in directing recommendations/appointments without requisition and after expiry.
- RPSC, as a constitutional body, has independent standing to appeal, even if the State did not.
- The Court sympathized with the petitioners’ plight due to prolonged litigation but held that law prevails over sympathy. It set aside all High Court orders, ruling the reserve lists had lapsed by the time petitions were filed or vacancies arose later.
Broader Implications
This verdict reinforces discipline in public recruitments, preventing reserve lists from becoming “infinite stocks” for claims. It addresses recurring service litigation burdening courts and urges timely, merit-based selections. The epilogue in the judgment highlights how protracted disputes aggravate administrative inefficiencies.
The ruling is likely to impact similar cases across states, emphasizing strict adherence to service rules and limiting judicial interference in policy matters like requisition and list validity
Lawcutor 