On October 9, 2025, the Hon’ble Supreme Court of India gave its order in the case of Ravi Oraon v. The State of Jharkhand & Ors. (2025 INSC 1212) and two related appeals made by Premlal Hembrom and Surendra Munda. By this path-breaking judgment, the Hon’ble Court restored the appellants’ services to their positions as Intermediate Trained Teachers, holding that the actions of the State authorities were arbitrary and against natural justice.
The three appeals were based on the recruitment drive undertaken by the Jharkhand Government in 2015 for hiring teachers for Classes I to V. The appellants, who belonged to the Scheduled Tribe category, were recruited after passing the selection process but were subsequently dismissed in 2016 on the basis that they had failed to obtain the minimum qualifying marks in their intermediate (Class XII) exams and that their graduation certificates were bogus. The Division Bench of the Jharkhand High Court maintained their dismissal, and hence the current appeal at the Supreme Court.
The Hon’ble Supreme Court, where Justice Dipankar Datta and Justice K.V. Viswanathan were present, considered whether marks obtained in vocational subjects could be incorporated while assessing the aggregate percentage of marks achieved in the intermediate examination. The Court also discussed whether the orders of termination, which were passed without serving a new show-cause notice, ran counter to the principles of natural justice.
On close examination of the Jharkhand Primary School Teacher Appointment Rules, 2012, the Court held that Rule 21, dealing with the preparation of merit lists, was not applicable for determining the eligibility to sit for the Teacher Eligibility Test (TET). Rather, Rule 4, concerning eligibility criteria, was held to be applicable. The Court observed that Rule 4 does not rule out marks earned in vocational subjects and thus the process indicated on the back of the mark sheet permission to include bonus marks from vocational subjects in the aggregate should be followed.
The Hon’ble Bench noted that the appellants have actually obtained over 40% marks after adding vocational marks, and thus were eligible for appointment under relaxation granted to Scheduled Tribe candidates. The Court also held that the termination orders were vitiated as the authorities altered the basis of the charge without giving the appellants a chance to defend themselves. The Court characterized the departmental action as “highhanded, arbitrary and violative of due process.”
In its relief orders, the Supreme Court overruled the Division Bench order and reinstated the Single Judge’s orders that had previously reinstated the appellants. The Court ordered that the appellants Ravi Oraon and Premlal Hembrom—will be considered to have been continuously in service from their initial date of appointment (December 2015) and are legally entitled to full arrears of pay, seniority, and service benefits. But the time lost on not being in service would not be included in experience for promotion.
Regarding Surendra Munda, who had died in August 2024, the Court directed his heirs shall be paid full arrears of pay from the date of dismissal till death and may apply for compassionate appointment under schemes applicable.
This ruling reinforces the Supreme Court’s diligence towards the safeguard of the rights of employees against arbitrary administrative action, further asserting that vocational subjects are a part of academic assessment. It further emphasizes that obedience to natural justice is unfeasible to do without, even in public employment cases.