Court Seeks Bar's Assistance on Whether Rajasthan Civil Services Appellate Tribunal Can Entertain Appeals on Answer Sheet Evaluation in Promotion Exams
In a significant development concerning departmental promotion disputes within Rajasthan Civil Services, the Rajasthan High Court (Jaipur Bench) on October 29, 2026, stayed an order passed by the Rajasthan Civil Services Appellate Tribunal directing re-examination of answer sheets for promotion from Sub-Inspector to Inspector. The High Court raised a crucial legal question regarding the Tribunal's jurisdiction to entertain appeals related to the evaluation of answer sheets in departmental examinations.
The case arose when the respondent, Sharwan Lal, challenged the alleged improper evaluation and non-award of correct marks in his departmental examination for promotion. The Tribunal had allowed his appeal and directed the State of Rajasthan to constitute a new board to re-examine his answer sheets, and if found eligible, permit him to participate in further promotion proceedings.
However, the State of Rajasthan contested the Tribunal's order, arguing that the grievance related to erroneous evaluation of answer sheets did not fall within the "service matters" as defined under Section 2(f) of the Rajasthan Civil Services (Service Matters Appellate Tribunals) Act, 1976. The Act specifically enumerates matters such as seniority, promotion, confirmation, fixation of pay, denial or variation of pay or pension, reversion, withholding of pension, and transfer as falling within the Tribunal's jurisdiction. The State's counsel contended that the evaluation of examination marks is not included in this list.
During the hearing, the High Court questioned whether the Tribunal had the authority to pass such a direction and noted that the earlier coordinate bench order permitting alternative remedies did not explicitly allow filing an appeal before the Tribunal. The Court stayed the operation of the Tribunal's order pending final determination of this jurisdictional issue.
Furthermore, the Court invited members of the Bar to assist in addressing the larger question of whether the Tribunal can entertain and decide appeals against evaluation of answer sheets in departmental promotion examinations conducted by the State. A notice to this effect will be published in the cause list, and the matter is listed for further hearing on December 7, 2026.
This judgment underscores the importance of clearly delineating the scope of appellate forums under service laws and highlights the judiciary's role in ensuring that statutory bodies function within their prescribed legal limits. It also signals to government employees and authorities that challenges to evaluation of departmental examinations might require alternative legal remedies rather than appeals before the Service Matters Appellate Tribunal.
Bottom Line:
Rajasthan Civil Services Appellate Tribunal - Jurisdiction - Challenge to improper evaluation of answer sheets in departmental examination for promotion - Prima facie, such grievance does not appear to fall within "service matters" as defined under Section 2(f) of the Rajasthan Civil Services (Service Matters Appellate Tribunals) Act, 1976 - Operation of Tribunal's order directing constitution of new board for re-examination stayed - Court invited assistance from Bar on issue of Tribunal's authority.
Statutory provision(s):
Rajasthan Civil Services (Service Matters Appellate Tribunals) Act, 1976 Section 2(f)
State of Rajasthan v. Sharwan Lal, (Rajasthan)(Jaipur Bench) : Law Finder Doc Id # 3011080
