The Supreme Court upheld the principle that the Karnataka State Administrative Tribunal (KSAT) is the designated court of first instance for service disputes, including recruitment matters. The High Court’s writ jurisdiction under Article 226 cannot be invoked when an effective statutory alternative remedy exists, barring exceptional constitutional circumstances not present in this case.
Facts Of The Case:
The State of Karnataka issued a recruitment notification in March 2022 for 15,000 Graduate Primary Teacher posts. Following examinations, a provisional select list was published in November 2022. This list excluded certain married women candidates who had applied under the Other Backward Classes (OBC) category because they submitted caste and income certificates in their fathers’ names instead of their husbands’. Consequently, they were placed in the general merit list. Aggrieved, some candidates filed a writ petition before the Karnataka High Court. A Single Judge allowed the petition in January 2023, quashing the provisional list and directing the State to consider the candidates under the OBC category based on their parental certificates. This led to a revised final select list in March 2023, which excluded 451 originally selected candidates. These excluded candidates and others challenged the Single Judge’s order before a Division Bench. The Division Bench, in October 2023, set aside the Single Judge’s judgment, holding the writ petitions were not maintainable as an alternative remedy existed before the KSAT, and relegated the matter to the Tribunal. Appeals were then filed before the Supreme Court by candidates from both the original and the revised select lists.
Procedural History:
The procedural history began with writ petitions filed by aggrieved married women candidates before the Karnataka High Court, challenging their exclusion from the OBC category in the provisional select list of November 2022. A Single Judge allowed these petitions in January 2023, directing their reconsideration under OBC quotas, which led to a revised final select list in March 2023. Candidates excluded by this revision, along with others, filed writ appeals before a Division Bench of the High Court. The Division Bench, in its impugned judgment of October 2023, set aside the Single Judge’s order, declaring the writ petitions non-maintainable due to the availability of an alternative remedy before the Karnataka State Administrative Tribunal (KSAT), and directed the parties to seek redress there. Subsequently, appeals from both sets of affected candidates were filed before the Supreme Court via special leave petitions, leading to the present judgment.