Jaipur | 4 September 2025 — The Rajasthan High Court (Jaipur Bench) has dismissed a batch of petitions pressing the State to fill every post under the decade-old Lower Division Clerk (LDC)-2013 recruitment, holding that the process has “reached its terminus” and candidates have no vested right to appointment merely by featuring in select/waiting lists. The single-judge bench of Justice Sameer Jain reserved judgment on August 20, 2025 and pronounced it on September 4, 2025.
What the case was about
The lead matter, Ramesh Chand Saini & Anr. v. State of Rajasthan & Ors. (S.B. Civil Writ Petition No. 18145/2024), challenged a departmental letter dated 7 September 2022 that limited appointments to about 4,000 LDC posts under the 2013 drive, despite the petitioners’ claim that far more vacancies were available. They sought directions to fill the “total advertised posts” and to issue a recruitment calendar for the remaining positions.
A decade of stops, starts—and restructuring
The Court traced the chequered history: an advertisement issued in 2013 notified 19,275 LDC vacancies across Panchayati Raj Institutions; 18,415 candidates qualified; 7,755 joined that year. Litigation over bonus-marks policy (the Archana line) halted appointments until the Supreme Court decided the controversy on 29 November 2016. Acting thereafter, and in compliance with Arjun Ram Nain (7 April 2017), 1,805 more appointments were made—taking the total to 9,560. Meanwhile, cadre restructuring fixed sanctioned LDC posts at 12,911, of which 11,179 stood filled; the department said around 4,000 remained vacant due to promotions and other factors, leading to the 7 September 2022 letter. Of those, 3,608 were filled, leaving 392—later said to be 333—vacant.
Note: While the judgment’s “indubitable facts” table records 19,275 advertised posts, minutes reproduced in Arjun Ram Nain refer to 19,246.
What the parties argued
Petitioners contended that once the State began recruitment, it could not cut back posts mid-stream (“rules of the game”), citing Tej Prakash Pathak; they also attacked late-stage changes to eligibility and computer-certificate norms, alleging “pick-and-choose” appointments under the same process.
State replied that the 2013 notification expressly reserved power to increase or decrease vacancies; no candidate gains an indefeasible right from a select list; and after 12 years the process could not be kept alive. Reliance was placed on Shankarsan Dash and related precedent. The State also pointed out that only 333 posts presently remained vacant.
The anchor: Division Bench ruling in Hari Om Meena
Justice Jain treated the controversy as no longer res integra in light of the Division Bench decision in Hari Om Meena v. State of Rajasthan (DBSAW No. 251/2025), which recorded the vacancy position, reiterated that inclusion in a select/waiting list does not confer a right to appointment, and held that a recruitment cannot be kept open for years after results. The Division Bench also noted a fresh recruitment had been initiated by advertisement dated 29 August 2024.
Court’s reasoning
Emphasizing judicial discipline, the Court said it would not “assume the mantle of cadre management” or unsettle a field already settled by a coordinate bench. Where an advertisement reserves liberty to vary vacancies, exercising that liberty does not alter the “rules of the game”; the prohibition on mid-process changes guards eligibility and selection method, not a fluctuating vacancy figure expressly left open by the employer. The petitioners showed no mala fides or arbitrariness warranting intervention.
The outcome
The entire batch of petitions was dismissed; no order as to costs; pending applications disposed.
Key timeline (as recorded by the Court)
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2013: Advertisement issued; 19,275 posts notified; 7,755 join after exam results.
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15 Jul 2013 → 29 Nov 2016: Litigation over bonus marks stalls appointments until Supreme Court’s decision.
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7 Apr 2017: Arjun Ram Nain directions; +1,805 appointments (total 9,560).
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Cadre restructuring: Sanctioned LDC posts fixed at 12,911; 11,179 filled.
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7 Sep 2022: Department tells districts to complete recruitment against ~4,000 vacancies; later 3,608 filled; 392 left, said to be 333.
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29 Aug 2024: Fresh LDC recruitment initiated (as noted by the Division Bench).
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4 Sep 2025: Present batch dismissed.
Bench & case details: Justice Sameer Jain; judgment reserved on 20/08/2025, pronounced on 04/09/2025; lead petition S.B. CWP No. 18145/2024 (Ramesh Chand Saini).
Bottom line: With Hari Om Meena binding and the employer’s vacancy-variation clause in place, the Court refused to reopen a 2013 process in 2025, declining to compel appointments beyond what currently stands sanctioned or available.
