KSAT as the Exclusive Court of First Instance in State Service Matters; High Courts’ Writ Jurisdiction Narrowed Absent Exceptional Circumstances — Supreme Court in Leelavathi N. v. State of Karnataka (2025 INSC 1242)

Court: Supreme Court of India

Bench: J.K. Maheshwari, J.; Vijay Bishnoi, J. (per Bishnoi, J.)

Date: 16 October 2025

Citation: 2025 INSC 1242

Introduction

This decision addresses a recurring and consequential question in Indian service jurisprudence: when must litigants first approach a statutory service tribunal (here, the Karnataka State Administrative Tribunal, “KSAT”), and when, if at all, can the High Courts directly entertain writ petitions under Article 226 in service recruitment disputes?

The case arises from a large-scale recruitment to 15,000 posts of Graduate Primary Teachers (Classes 6–8) in Karnataka. The controversy centers on the treatment of certain married women candidates seeking Other Backward Classes (OBC) reservation on the basis of caste-cum-income certificates: whether the relevant certificate should be in the name of the husband or the father; the interpreting authority’s power to assess such certificates; and whether the High Court could directly entertain writ petitions bypassing KSAT.

The Supreme Court’s ruling does not decide the substantive merits of OBC eligibility for married women candidates. Instead, it lays down a clear procedural directive: KSAT is the court of first instance for State service matters. In reaffirming the Constitution Bench in L. Chandra Kumar v. Union of India (1997) 3 SCC 261, the Court clarifies that exceptional circumstances permitting writs bypassing tribunals are rare, and notably distinguishes—and demotes the precedential weight of—T.K. Rangarajan v. State of Tamil Nadu (2003) 6 SCC 581 in this context.

Litigation Background and Procedural History

• Recruitment Notification: 21 March 2022 for 15,000 Graduate Primary Teachers across 35 educational districts.
• Examinations: 21–22 May 2022; Results: 17 August 2022; Provisional Select List: 18 November 2022.
• Core Trigger: Several married women candidates applying under OBC categories (2A, 2B, 3A, 3B) submitted caste-cum-income certificates issued in their fathers’ names rather than in their husbands’ names. The selecting authority treated them as ineligible for OBC reservation and shifted them to General Merit.
• Single Judge’s Orders (30 January 2023): Allowed writ petitions (W.P. No. 23752/2022), quashed the provisional list insofar as it placed such candidates in General Merit, and directed the State to treat them as OBC candidates based on the appended certificates. The Judge also:
  • Held writ petitions maintainable despite KSAT’s jurisdiction (relying on T.K. Rangarajan).
  • Held creamy layer status is determined by parents’ status, not spouse’s, relying on Surinder Singh v. PSEB (2014) 15 SCC 767.
  • Held DPPI lacked jurisdiction to interpret certificates contrary to competent authority’s issuance.
• Consequences: A fresh provisional list was issued on 27 February 2023 implementing the Single Judge’s directions. Approximately 451 candidates who were initially included were displaced due to changed merit positions. Final select list was published on 8 March 2023.
• Division Bench (12 October 2023): In writ appeals, set aside the Single Judge’s judgment on maintainability, relegated all parties to KSAT as the proper first-instance forum. As interim relief, allowed appointments per the 8 March 2023 final list (subject to specified conditions).
• Supreme Court Interim Orders:
  • 3 January 2024: Stayed operative directions of the Division Bench permitting appointments; kept appointment letters in abeyance.
  • 22 January 2024: Clarified that 11,494 candidates already working would continue, subject to the outcome; 481 posts tied to the married women–OBC issue to be kept aside.
  • 4 October 2024: Permitted filling remaining vacancies, reserving 500 posts.
• Supreme Court Final Decision (16 October 2025): Appeals dismissed; Division Bench order upheld; matters to proceed before KSAT; interim directions made absolute with clarification that 500 reserved posts will be filled as per KSAT’s final decision; KSAT requested to decide expeditiously, preferably within six months of filing.

Issues Before the Supreme Court

1. Whether the High Court could entertain writ petitions directly under Article 226 in a recruitment/service dispute that falls squarely within KSAT’s jurisdiction under Section 15 of the Administrative Tribunals Act, 1985.
2. Whether the Division Bench erred by not restoring the provisional select list dated 18 November 2022 after setting aside the Single Judge’s decision.

The Supreme Court confined itself to maintainability and forum, leaving the substantive OBC eligibility issues to KSAT.

Summary of the Judgment

• KSAT is the court of first instance for State service matters within Section 15 of the Administrative Tribunals Act, 1985; writ petitions before the High Court are not maintainable except in narrowly carved exceptional cases consistent with L. Chandra Kumar.
• Single Judge’s reliance on T.K. Rangarajan to bypass KSAT was misplaced. The Supreme Court clarified that Rangarajan neither departs from L. Chandra Kumar nor establishes a general precedent for bypassing tribunals; at best, it is a case-specific exercise of Article 142 and non-binding on the rule of forum.
• No “unprecedented extraordinary situation” existed here. Disputes over certificate-based eligibility in recruitment are routine and suited for tribunal adjudication.
• No revival of the provisional list. Inclusion in a provisional list does not create an accrued right. Reviving it would cause confusion and administrative complexity.
• Interim orders made absolute. Earlier interim arrangements continue. The 500 reserved posts will be filled in accordance with KSAT’s final decision.
• Expedited KSAT proceedings. The Court expressed that KSAT should endeavor to decide the applications expeditiously, preferably within six months of filing.

Detailed Analysis

A. Precedents and Their Influence

• L. Chandra Kumar v. Union of India, (1997) 3 SCC 261
  • Constitution Bench: Tribunals under Articles 323-A and 323-B are courts of first instance for the areas of law they cover. Their decisions are subject to High Court judicial review under Articles 226/227, but litigants cannot bypass the tribunals.
  • The present judgment reaffirms this bedrock principle and applies it strictly to State service disputes within Section 15 of the 1985 Act.
• Rajeev Kumar v. Hemraj Singh Chauhan, (2010) 4 SCC 554
  • Confirms the L. Chandra Kumar mandate: High Courts cannot be treated as courts of first instance in service disputes over which CAT/State ATs have jurisdiction.
  • Relied upon to underscore that appellants should approach KSAT first.
• T.K. Rangarajan v. State of Tamil Nadu, (2003) 6 SCC 581
  • Concerned mass dismissal of about two lakh employees post strike. High Court’s direct intervention recognized due to truly exceptional circumstances.
  • Here, the Supreme Court clarifies it does not dilute L. Chandra Kumar. The Court states that, at best, Rangarajan reflects Article 142–based exceptional relief and is not a binding precedent to bypass tribunals in ordinary service disputes. This is a significant recalibration of how Rangarajan may be invoked in future.
• Nivedita Sharma v. COAI, (2011) 14 SCC 337; Radha Krishan Industries v. State of HP, (2021) 6 SCC 771; PHR Invent Educational Society v. UCO Bank, (2024) 6 SCC 579
  • These decisions articulate the rule of alternate remedy and the limited exceptions when writs may still lie: enforcement of fundamental rights; patent lack of jurisdiction; breach of natural justice; or vires of parent legislation under challenge.
  • Applied here to hold that none of those exceptions were attracted.
• Thansingh Nathmal (AIR 1964 SC 1419); Titaghur Paper Mills, (1983) 2 SCC 433; Mafatlal, (1997) 5 SCC 536; Whirlpool, (1998) 8 SCC 1; Harbanslal Sahnia, (2003) 2 SCC 107
  • These decisions contribute to the architecture of writ prudence and restraint when efficacious alternate remedies exist, and the exceptions that justify departure.
  • The Court uses this line to emphasize that duly empowered tribunals should not be bypassed.
• Surinder Singh v. Punjab State Electricity Board, (2014) 15 SCC 767
  • Cited before the Single Judge to reason that caste is by birth and creamy layer is determined with reference to parents, not spouse. The Supreme Court does not decide this merits issue; it remains open for KSAT.

B. Legal Reasoning

1. Jurisdictional Primacy of KSAT: The Court begins by noting that no party seriously disputes KSAT’s jurisdiction over the subject matter. Section 15 of the Administrative Tribunals Act, 1985, confers exclusive jurisdiction on State Administrative Tribunals over recruitment and service matters under the State.
2. Rule of Alternate Remedy and Exceptions: Applying L. Chandra Kumar and subsequent case law, the Court reiterates that High Courts should not entertain writs when a competent tribunal is the first-instance forum. Exceptions (fundamental rights enforcement; absence of jurisdiction; natural justice violations; challenge to parent statute’s vires) are narrow and inapposite here.
3. Distinguishing T.K. Rangarajan: The Single Judge’s approach—invoking Rangarajan to justify direct writ intervention—was rejected. The Supreme Court stresses that Rangarajan was an extraordinary scenario and does not create a general carveout from L. Chandra Kumar. The Court adds that Rangarajan is best understood as an Article 142–driven, fact-specific relief and is not binding in the sense of permitting bypass of tribunals in ordinary service disputes.
4. No Exceptional Circumstances: Certificate-verification disputes in recruitment are routine incidents within administrative processes. They do not present a systemic collapse or extraordinary emergency warranting High Court intervention bypassing the tribunal.
5. KSAT’s Adequacy and Powers: The Court details the Tribunal’s procedural tools and powers under the 1985 Act, including Sections 22 (procedure; civil court powers), 24 (interim relief, even ex parte in exigency), 27 (execution), and the Karnataka rules and regulations ensuring expedition (e.g., six-month indicative timeline). KSAT is well-equipped to “do complete justice.”
6. No Right from Provisional Select Lists: On the appellants’ plea to restore the provisional list of 18 November 2022, the Court holds that provisional inclusion confers no accrued right. Reviving it would create confusion and administrative complexity.
7. Interim Architecture Preserved: The Court makes earlier interim orders absolute, clarifies the status of appointees, and keeps 500 posts reserved, to be filled per KSAT’s final adjudication. It also urges KSAT to decide expeditiously, preferably within six months.

C. Impact and Implications

• High Courts’ Gatekeeping Strengthened: This judgment tightens writ maintainability standards in State service matters, reaffirming that tribunals must be the first port of call. It will likely result in prompt dismissal of similar writ petitions as not maintainable, with liberty to approach KSAT.
• Rangarajan’s Role Narrowed: By characterizing Rangarajan as essentially an Article 142 exercise and non-binding on forum, the Court significantly limits reliance on that case to bypass tribunals. This will steer litigants back to tribunals unless truly exceptional exigencies exist.
• Administrative Continuity Preserved: By refusing to revive a provisional list and preserving the interim framework (including 500 reserved posts), the Court balances systemic stability with fairness pending KSAT’s decision.
• Substantive Questions Remain Open: The merits of whether married women OBC candidates should be assessed on parental or spousal caste-cum-income certificates, and the selecting authority’s jurisdiction to interpret such certificates, remain to be authoritatively decided—now by KSAT in the first instance.
• Tribunal Workload and Timelines: The explicit six-month preference and recognition of KSAT’s procedural powers signal judicial expectations for speedy resolution. Litigants should prepare concise, well-documented pleadings to facilitate expedition.

Complex Concepts Simplified

• Administrative Tribunals Act, 1985 (ATA 1985): A statute creating specialized tribunals (e.g., KSAT) to adjudicate service matters. Section 15 confers exclusive first-instance jurisdiction for State service disputes; Sections 22, 24, 27 empower procedure, interim relief, and execution.
• L. Chandra Kumar Principle: Tribunals are the first-instance forums in their designated fields. High Courts’ writ jurisdiction survives, but typically only after tribunal adjudication, and subject to the narrow exceptions.
• Article 226/227 vs. Alternate Remedy: High Courts can issue writs, but as a matter of judicial prudence, they defer when a suitable statutory remedy exists—unless exceptional grounds (such as lack of jurisdiction, violation of natural justice, or constitutional vires challenges) are present.
• Article 142 Orders: The Supreme Court’s power to do complete justice in any cause. Such orders may be highly fact-specific and not uniformly precedential in other contexts, particularly on points not generally laid down as rules.
• Creamy Layer and OBC Certificates: “Creamy layer” refers to socially advanced individuals within OBCs who are ineligible for reservation benefits based on income/status thresholds. The debate here concerns whether a married woman’s OBC status/creamy layer should be judged by her parents or spouse—a question not decided in this judgment.
• Provisional vs. Final Select List: A provisional list is tentative and confers no vested right; the final list is the operative selection outcome, subject to legal challenges.
• DPPI’s Role: Deputy Director of Public Instruction acted as the Selecting Authority. Whether it could “interpret” certificates was questioned before the Single Judge; the Supreme Court leaves this jurisdictional merits question for KSAT.

Practical Guidance and Next Steps

• For Candidates:
  • File a properly constituted application before KSAT. Ensure all certificate-related documents, government orders, and recruitment notifications are annexed.
  • Seek interim relief under Section 24 if warranted; KSAT can grant ex parte interim protection in urgent situations, subject to statutory safeguards.
• For the State/Recruiting Authorities:
  • Preserve records of certificate verifications, rationale for acceptance/rejection, and compliance with government orders and recruitment rules.
  • Abide by the Supreme Court’s interim framework: the 500 reserved posts are to be filled as per KSAT’s final decision.
• For Practitioners:
  • Advise clients to approach KSAT first in State service disputes unless an exceptional ground squarely fits a recognized writ exception.
  • When invoking exceptions, clearly plead and substantiate the jurisdictional/natural justice/vires ground with precision; generic inconvenience will not suffice.

Conclusion

The Supreme Court in Leelavathi N. v. State of Karnataka delivers a clear, system-strengthening message: in State service matters, KSAT is the exclusive court of first instance, and High Courts should not be approached directly save for narrowly circumscribed exceptions. By recalibrating the reliance on T.K. Rangarajan and reaffirming L. Chandra Kumar, the Court curtails the increasing tendency to bypass tribunals in recruitment disputes.

Equally, the Court resists the administrative upheaval that would follow from reviving a provisional select list and preserves a balanced interim framework—including 500 reserved posts—pending a merits determination by KSAT. Importantly, the substantive questions concerning the assessment of OBC status for married women candidates and the Selecting Authority’s interpretive jurisdiction remain open and will now be addressed by KSAT with an expectation of expedition.

Key takeaway: The judgment fortifies the tribunal-first architecture of Indian administrative justice, ensuring that specialized forums address service grievances promptly and comprehensively, with High Courts exercising review in due course rather than at the threshold.