The Indian judiciary has long been the guardian of constitutional rights, ensuring that the principles of justice, equality, and fairness are upheld across the nation. One of the recent judgments that highlight the critical role of the judiciary in protecting these rights is the Supreme Court’s decision in the case Rekha Sharma vs. Rajasthan High Court, Jodhpur & Anr., where the Court examined the issue of non-declaration of separate cut-off marks for Persons with Benchmark Disabilities (PWD) under Overall Horizontal Reservation in the context of the Rajasthan Judiciary 2024 recruitment.
In this blog post, we delve into the Supreme Court’s ruling, the concepts of horizontal and vertical reservations, and how constitutional remedies safeguard the rights of citizens, particularly under Articles 14, 16, and 21 of the Indian Constitution, within the framework of Rajasthan Judiciary 2024.
Table of Contents
1. Background of the Case: Rekha Sharma vs. Rajasthan High Court
The case in question arose from the direct recruitment process for the posts of Civil Judge and Judicial Magistrate in Rajasthan, under the Rajasthan Judiciary 2024. The appellants, who were persons with benchmark disabilities (PWD), challenged the recruitment process on the grounds that the cut-off marks for their category under Overall Horizontal Reservation were not declared. They argued that this omission was arbitrary and violative of their fundamental rights under Articles 14, 16, and 21 of the Constitution.
1.1 The Issue at Hand
The central issue was whether the non-fixation of separate cut-off marks for the PWD category, which falls under Overall Horizontal Reservation, was arbitrary and discriminatory in the Rajasthan Judiciary 2024 recruitment process. The appellants contended that since cut-off marks were declared for other categories, failing to declare them for the PWD category was a violation of their right to equality.
2. Understanding Horizontal and Vertical Reservations
To fully grasp the Supreme Court’s decision, it’s essential to understand the difference between Horizontal and Vertical Reservations in the Indian reservation system, particularly in the context of Rajasthan Judiciary 2024.
2.1 Vertical Reservation
Vertical Reservation refers to the reservation provided to various social categories such as Scheduled Castes (SC), Scheduled Tribes (ST), Other Backward Classes (OBC), and Economically Weaker Sections (EWS). These reservations are applied vertically across the total number of seats in a specific category, including those in the Rajasthan Judiciary 2024 recruitment.
2.2 Horizontal Reservation
Horizontal Reservation, on the other hand, cuts across vertical categories and applies to specific groups like women, persons with disabilities (PWD), or ex-servicemen. Horizontal Reservation can be of two types:
- Compartmentalised Horizontal Reservation: Where vacancies are reserved proportionately in each vertical category.
- Overall Horizontal Reservation: Where the reservation is applied across the total number of posts, not confined to specific vertical categories, as seen in the Rajasthan Judiciary 2024 recruitment.
3. Supreme Court’s Ruling: Key Observations
In the Rekha Sharma case, the Supreme Court, in its judgment delivered on August 21, 2023, made several key observations regarding the nature of Horizontal Reservations and the non-declaration of separate cut-off marks for the PWD category under Overall Horizontal Reservation in the Rajasthan Judiciary 2024 recruitment.
3.1 Not Arbitrary or Violative of Fundamental Rights
The Court held that the non-fixation of separate cut-off marks for the PWD category under Overall Horizontal Reservation in the Rajasthan Judiciary 2024 recruitment was neither arbitrary nor violative of Articles 14, 16, and 21 of the Constitution. The bench comprising Justice Bela M Trivedi and Justice Satish Chandra Sharma emphasized that when a category falls under Overall Reservation, it is not necessary for the selection authorities to declare separate cut-off marks for such a category.
3.2 Reference to Previous Judgments
The judgment referred to the case of Anil Kumar Gupta vs. State of U.P. (1995), where the Supreme Court distinguished between Compartmentalised and Overall Horizontal Reservations. The Court reiterated that in the case of Overall Horizontal Reservation, the special reservation candidates (like PWD) must be accommodated within the total posts reserved, either by adjusting them against any of the social/vertical reservations or otherwise. Hence, it is not required to declare a separate cut-off for them, which was the scenario in the Rajasthan Judiciary 2024 recruitment.
3.3 Application to the Rekha Sharma Case
In the Rekha Sharma case, the Court observed that the recruitment advertisement for Rajasthan Judiciary 2024 specifically provided Overall Reservation for the PWD category, meaning that PWD candidates were to be adjusted within the overall posts without the need for separate cut-off marks. As such, the respondents’ decision not to declare a separate cut-off was in line with the principles of Overall Horizontal Reservation and was upheld by the Court.
5. The Role of Judiciary in Upholding Constitutional Remedies
The judiciary’s role in interpreting and enforcing constitutional remedies cannot be overstated. By adjudicating cases like Rekha Sharma vs. Rajasthan High Court, the Supreme Court ensures that the principles of justice, equality, and fairness are consistently applied, protecting citizens’ rights and maintaining the integrity of the legal system, particularly in significant recruitment processes like Rajasthan Judiciary 2024.
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6. Conclusion
The Supreme Court’s ruling on the PWD cut-off marks in the Rajasthan Judiciary 2024 recruitment underscores the importance of understanding the legal framework surrounding reservations and constitutional remedies. By interpreting these provisions correctly, the judiciary ensures that the rights of all citizens are protected, and that the recruitment processes remain fair and transparent.
Aspiring judiciary candidates must equip themselves with a thorough understanding of these legal principles, and resources like Doon Law Mentor can provide the guidance necessary to excel in exams like Rajasthan Judiciary 2024. Knowledge of constitutional remedies is not just crucial for legal professionals, but it is also the foundation for defending and upholding the rule of law in India.
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