Managing Director, M.P. State Agricultural Marketing Board v. Harpal Singh; 2025 INSC 1490 - Compassionate Appointment
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Compassionate Appointment - The policy of compassionate appointment is not a concession, largesse or mercy shown to hapless dependents of a deceased employee, but a structured response of the State to ensure that the death of an employee does not mark the beginning of economic calamity for those left behind (Para 11)- a narrow or mechanical construction of the rules governing compassionate appointment cannot be permitted to override the welfare-oriented purpose of the scheme. Where a procedural rigidity ceases to advance the humanitarian intent of the policy and instead operates as an obstacle to its effective implementation, such a procedure must be construed liberally to ensure that justice is not sacrificed at the altar of technicality.(Para 17) -Compassionate appointment, being a narrowly tailored welfare measure, stands on a distinct footing and does not militate against the principles governing open competition in public employment. (Para 19)
Case Info
Case Details
- Case name: Managing Director, M.P. State Agricultural Marketing Board and Ors. v. Harpal Singh and Ors.
- Neutral citation: 2025 INSC 1490
- Coram: Sanjay Karol, J.; Nongmeikapam Kotiswar Singh, J.
- Judgment date: November 28, 2025
- Disposition: Civil Appeal dismissed; direction to consider Class-IV compassionate appointment within six weeks.
Caselaws and Citations
- Haryana State Electricity Board v. Hakim Singh, (1997) 8 SCC 85.
- General Manager, State Bank of India v. Anju Jain, (2008) 8 SCC 475.
- Sadananda Halo v. Momtaz Ali Sheikh, (2008) 4 SCC 619.
- Vijendra Kumar Verma v. Public Service Commission, (2011) 1 SCC 150.
- Manish Kumar Shahi v. State of Bihar, (2010) 12 SCC 576.
- Sushil Kumar Sen v. State of Bihar, (1975) 1 SCC 774.
Statutes/Laws/Policies Referred
- Constitution of India: Article 14; Article 16; Part IV (Directive Principles), particularly Article 39.
- Government Policy: General Administration Department, Government of Madhya Pradesh Memorandum No. C-3-12/2013/1/3 dated 29 September 2014, including:
- Clause 6.5: CPCT/computer qualification requirement with 3-year period + possible 1-year extension, failing which services may be terminated.
- Clause 13.1: No second compassionate appointment on another post.
- Administrative Requirement: Computer Proficiency Certification Test (CPCT) and listed acceptable computer qualifications (UGC-recognized diplomas, DOEACC, Modern Office Management from Govt Polytechnic, COPA from Govt ITI).
