Ravi Oraon vs State of Jharkhand 2025 INSC 1212 - Jharkhand Primary School Teacher Appointment Rules- Natural Justice

Jharkhand Primary School Teacher Appointment Rules, 2012 - Rule 4,21- The procedure that Rule 21 enshrined is only to be used for the purpose of preparation of merit list and Rule 4 does not provide for exclusion of marks secured in the vocational subject (Para 36) - Marks secured in the vocational subject is a way for a candidate to improve his/her overall percentage of marks -A vocational subject, though optional, would place an additional burden on an examinee which he/she shoulders in the fervent hope of improving his/her overall percentage.  (Para 23)

Natural Justice - where the noticee successfully defends the charge against him but is made to suffer civil consequences because the notifier finds the noticee guilty of a different charge in respect whereof he is not put to notice. In such a case, the finding of guilt which is at variance with the original charge without proper opportunity to respond offends due process and renders any order or action unsustainable. (Para 33)

Case Info

  • Case name: Ravi Oraon v. State of Jharkhand & Ors.; with Premlal Hembrom v. State of Jharkhand & Ors.; and Surendra Munda v. State of Jharkhand & Ors.
  • Neutral citation: 2025 INSC 1212.
  • Coram: Justice Dipankar Datta and Justice K.V. Viswanathan.
  • Judgment date: October 09, 2025.

Caselaws and citations

  • Escorts Farms Ltd. v. Commissioner, Kumaon Division, Nainital, V.P. & others, (2004) 4 SCC 281.

Statutes / laws referred

  • Article 309 of the Constitution of India (proviso) — enabling the framing of service rules.
  • Jharkhand Primary School Teacher Appointment Rules, 2012:
    • Rule 3 (conduct of eligibility examination).
    • Rule 4 (eligibility criteria and 5% relaxation for SC/ST/disabled).
    • Rule 21 (merit list preparation; exclusion of additional subject marks for educational merit point).
  • National Council for Teacher Education (NCTE) Regulations 2002 (recognition, standards, activities).