Recruitment — Essential Qualification — Driving Licence — “Continuously for Two Years” — Motor Vehicles Act, 1988 (as amended by Act 32 of 2019) — Interpretation — Renewal after Expiry — Effect — Equality in Public Employment

Recruitment — Essential Qualification — Driving Licence — “Continuously for Two Years” — Motor Vehicles Act, 1988 (as amended by Act 32 of 2019) — Interpretation — Renewal after Expiry — Effect — Equality in Public Employment

1. Recruitment notification — Eligibility condition must be strictly complied with
   Where the recruitment notification mandates possession of a valid driving licence “continuously for a period of full two years and above as on the date of notification”, the condition has to be satisfied strictly and literally. (Paras 22–25, 32, 33)

2. Driving licence — Expiry and renewal — No automatic continuity after amendment
   After the Motor Vehicles (Amendment) Act, 2019, a driving licence does not continue to be effective even for a single day after expiry unless renewed, as the proviso extending validity for 30 days stands omitted. (Paras 27–30)

3. Renewal within one year — Renewal operates from date of renewal, not expiry
   Section 15 of the Motor Vehicles Act, 1988, as amended, merely provides a window for renewal but does not condone or validate the interregnum period between expiry and renewal. (Paras 30–31, 33)

4. Meaning of “continuously” — Literal and legal interpretation
   The term “continuously” in recruitment notifications must be given its ordinary meaning of “uninterruptedly; without intermission”, denoting actual and lawful capacity to drive during the entire period. (Paras 33–34)

5. Expiry of licence — Legal disability to drive
   From the date of expiry of a driving licence, the holder is legally barred from driving, and such period cannot be treated as part of continuous possession of licence merely because renewal was obtained later. (Paras 29–33)

6. Driving test — Cannot cure lack of eligibility
   Subsequent qualification in a driving test cannot override or dilute the threshold eligibility condition prescribed in the recruitment notification. (Paras 34)

7. Equality in public employment — No undue benefit to ineligible candidates
   Grant of benefit to candidates who were ineligible as on the cut-off date would violate Article 14, particularly when similarly placed persons did not apply considering themselves ineligible. (Paras 34)

8. High Court error — Interference justified
   The High Court erred in holding that renewal of licence after expiry relates back to the date of expiry and satisfies the requirement of continuous possession. (Paras 22, 31, 35)

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ANALYSIS OF FACTS

1. The Telangana State Level Police Recruitment Board issued Notifications dated 25.04.2022 and 20.05.2022 for recruitment to posts of Drivers in police and fire services, mandating possession of valid driving licences continuously for two years prior to the notification dates (Paras 7, 25).

2. The private respondents’ driving licences had expired within the two-year period, though they were subsequently renewed within one year of expiry (Paras 9, 19).

3. The respondents were disallowed from participating in the written examination on the ground that they lacked continuous licence validity (Para 9).

4. The learned Single Judge allowed the writ petitions holding that renewal operated from the date of expiry and therefore there was no break (Para 10).

5. The Division Bench affirmed the Single Judge’s view (Para 11).

6. The Recruitment Board and eligible candidates challenged the High Court judgments before the Supreme Court (Paras 4–6).

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ANALYSIS OF LAW

1. Statutory interpretation — Effect of Amendment Act, 2019
   The Court held that omission of the proviso to Section 14 extending licence validity by 30 days was a deliberate legislative change and must be given full effect (Paras 27–31).

2. Section 15 — Limited scope
   Section 15 only prescribes the period within which renewal may be sought; it does not validate the period between expiry and renewal (Paras 30–31).

3. Literal rule of interpretation
   Applying the plain-meaning rule, the Court held that continuity cannot be inferred where the statute expressly removes automatic extension (Paras 29–31).

4. Purpose of recruitment condition
   Continuous possession of licence ensures regular driving practice, especially for police and emergency services, and is neither arbitrary nor unreasonable (Paras 32–33).

5. Driving test — Supplementary, not substitutive
   The driving test is only a further filter and cannot compensate for failure to meet basic eligibility criteria (Para 34).

6. Doctrine of equality
   Extending benefit to ineligible candidates would prejudice those who did not apply, believing themselves to be ineligible, thereby violating equality principles (Para 34).

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FINAL RESULT

• The Civil Appeals were allowed.

• The impugned judgments of the High Court were set aside.

• The writ petitions filed by candidates whose driving licences were not valid continuously for two years prior to the notifications stood dismissed.

• Eligibility condition in the recruitment notifications was upheld in its strict sense. (Para 35)