Court rules ambiguity in experience requirements benefits candidates; rejects insistence on petrol engine experience in heavy vehicles, orders appointment of eligible candidates within two months
In a significant ruling on October 6, 2026, the Karnataka High Court (Division Bench comprising Mr. R. Devdas and Dr. K. Manmadha Rao, JJ.) dismissed the State of Karnataka's writ petition challenging the Karnataka State Administrative Tribunal's (KSAT) decision regarding the recruitment of Motor Vehicle Inspectors (MVIs). The judgment addresses critical ambiguities in the prescribed work experience qualifications and mandates the issuance of appointment orders to eligible candidates who had been denied appointments on technical grounds.
The recruitment process, initiated under a 2016 notification for 150 MVI posts in the Transport Department, mandated candidates to have "work experience of at least one year in a reputed automobile workshop which undertakes repairs of both Light Motor Vehicles (LMVs), Heavy Goods Vehicles (HGVs), and Heavy Passenger Vehicles (HPVs) fitted with petrol and diesel engines." The core issue before the Court was the interpretation of the experience requirement - whether candidates must have one full year of experience in each category of vehicle or whether aggregate experience across categories suffices.
The Court found the provision ambiguous and held that the recruitment rules do not require a candidate to have one year's experience in each class of vehicle separately. Instead, if the combined experience from one or more workshops covering the prescribed vehicle types totals one year or more, the requirement is met. This interpretation aligns with the earlier decision of the KSAT and is supported by Supreme Court jurisprudence emphasizing that ambiguities in eligibility criteria should be resolved in favor of candidates.
Another pivotal aspect of the case was the challenge to candidatures rejected due to lack of experience with HGVs and HPVs fitted with petrol engines. The Court observed that petrol engine vehicles in these categories have not been in use in India for several decades. Certificates purportedly showing such experience, especially those issued by State Transport Corporations like KSRTC and BMTC, were deemed false. The Court condemned the acceptance of such certificates by recruiting authorities and held that candidates cannot be penalized for lacking experience that is impossible to obtain. It invoked the legal maxim "lex non cogit ad impossibilia" (law does not compel the impossible) to emphasize that the law excuses performance when conditions are impossible to fulfill.
Further, the Court instructed the Transport Department to reconsider cases where Deputy Commissioners' adverse verification reports had led to rejection. Physical verification of workshops that failed to disclose supporting documents must be redone, and fresh reports submitted. Based on these, the Commissioner of Transport must reconsider and issue appointment orders to candidates fulfilling the combined experience criterion, irrespective of experience in petrol engine HGVs or HPVs.
The Court's order directs that appointment orders be issued expeditiously, within two months of receiving the certified judgment copy, and that such candidates be granted all consequential benefits including seniority on par with already appointed candidates.
This judgment not only clarifies the interpretation of experience qualifications under the Motor Vehicles Act, 1988 and Karnataka's Cadre and Recruitment Rules, 2013, but also safeguards candidates' rights against rigid and impractical recruitment conditions. It underscores the judiciary's role in preventing injustice arising from ambiguous rules and obsolete requirements.
Bottom Line:
Recruitment to the post of Motor Vehicle Inspector - Ambiguity in prescribed experience qualification must enure to the benefit of candidates - Aggregate/combined experience of one year from one or more workshops dealing with prescribed classes of vehicles is sufficient - Candidates cannot be denied appointment for lack of experience in HGV/HPV petrol vehicles, as such requirement is impossible of compliance and authorities cannot act on false certificates issued by State transport corporations.
Statutory provision(s):
Motor Vehicles Act, 1988 Section 213(4), Cadre and Recruitment Rules, 2013
State of Karnataka v. Sri Srinivasa B N, (Karnataka)(DB) : Law Finder Doc Id # 2992093
