Service Law — Promotions in Kerala Technical Education Service — Effect of prior Supreme Court judgment — High Court cannot indirectly unsettle benefits granted by Supreme Court — Finality of judicial orders — Held, once promotions were granted in compliance with specific directions of Supreme Court and contempt petition disposed noting compliance, High Court could not pass directions adversely affecting such beneficiaries — Appeal allowed to limited extent. (Paras 13–15) The appellants had secured promotion pursuant to orders of this Court in earlier proceedings, including compliance recorded in contempt jurisdiction. The High Court, while deciding connected matters, issued directions which had the effect of prejudicially impacting the appellants’ promotional benefits though they were not parties before it. The Supreme Court held that the High Court could not revisit or disturb the finality attached to orders passed by this Court, particularly where such orders had attained finality and were acted upon. Ratio Decidendi: Benefits flowing from a final judgment of the Supreme Court cannot be nullified or diluted by subsequent High Court directions in proceedings to which the beneficiaries were not parties.

advocatemmmohan

Service Law — Promotions in Kerala Technical Education Service — Effect of prior Supreme Court judgment — High Court cannot indirectly unsettle benefits granted by Supreme Court — Finality of judicial orders — Held, once promotions were granted in compliance with specific directions of Supreme Court and contempt petition disposed noting compliance, High Court could not pass directions adversely affecting such beneficiaries — Appeal allowed to limited extent. (Paras 13–15)

The appellants had secured promotion pursuant to orders of this Court in earlier proceedings, including compliance recorded in contempt jurisdiction. The High Court, while deciding connected matters, issued directions which had the effect of prejudicially impacting the appellants’ promotional benefits though they were not parties before it. The Supreme Court held that the High Court could not revisit or disturb the finality attached to orders passed by this Court, particularly where such orders had attained finality and were acted upon.

Ratio Decidendi: Benefits flowing from a final judgment of the Supreme Court cannot be nullified or diluted by subsequent High Court directions in proceedings to which the beneficiaries were not parties.

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Service Rules — AICTE Regulations vis-à-vis State Rules framed under Article 309 — Repugnancy — Applicability — Issue not reopened qua appellants due to finality of earlier Supreme Court decision. (Paras 3–6, 9, 14–15)

While the High Court held that the State Rules would be void to the extent repugnant to AICTE Regulations and that Ph.D. qualification became mandatory after 05.03.2010, the Supreme Court clarified that such findings could not operate to the detriment of appellants whose cases stood concluded by prior judgments of this Court interpreting Rule 6A and AICTE notifications.

Ratio Decidendi: Even if a High Court correctly interprets regulatory supremacy in general, such interpretation cannot reopen or override rights crystallised under binding Supreme Court judgments.

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Natural Justice — Persons not parties to earlier proceedings — Remedy available — Review or fresh proceedings before appropriate forum — Reliance on precedents. (Paras 16–20)

The Court addressed grievances of intervenors and petitioner in connected SLP who were not parties to earlier proceedings but claimed to be adversely affected by High Court judgment. Referring to established precedents, it reiterated that affected non-parties may seek appropriate remedies including review on limited grounds or approach the competent tribunal afresh, depending on statutory framework.

Ratio Decidendi: A person adversely affected by a judicial decision in proceedings to which he was not a party is not remediless; appropriate recourse lies in review on limited grounds or independent proceedings before the competent forum.

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Finality of Litigation — Public Policy — Judicial discipline — High Court must respect binding directions of Supreme Court under Article 141. (Paras 14–15)

The Court emphasised that once it had granted relief to the appellants and compliance was recorded, judicial discipline required subordinate courts to honour such finality. Any contrary approach would undermine certainty in service jurisprudence and violate principles of finality.

Ratio Decidendi: Judicial discipline mandates that High Courts cannot issue directions that effectively reopen or undermine rights conclusively settled by the Supreme Court.

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Relief Granted: Appeal allowed to limited extent; clarified that nothing in impugned High Court judgment shall affect appellants’ career prospects in view of special facts. Connected SLP and intervention applications disposed of with liberty to pursue appropriate remedies before competent forum. (Paras 15–20)**