Case Title: Ravi Oraon vs. The State of Jharkhand & Ors.
(Along with Civil Appeal Nos. 11749 & 11750 of 2025 - Premlal
Hembrom and Surendra Munda vs. The State of Jharkhand & Ors.)
Case No.: Civil Appeal No. 11748 of 2025
Citation: 2025 INSC 1212
Date of Judgment: October 9, 2025
In a significant judgment restoring justice to three Jharkhand
teachers who were wrongfully dismissed, the Supreme Court of India
on Thursday set aside the orders of the Jharkhand High Court that
had upheld their termination. The apex court ruled that the
dismissal of Ravi Oraon, Premlal Hembrom, and Surendra Munda was
illegal and violated the principles of natural justice.
Delivering the verdict, a Bench comprising Justice Dipankar Datta
and Justice K.V. Viswanathan held that the State authorities acted
'in a high-handed, arbitrary and illegal manner' by terminating the
teachers without giving them a fair opportunity to respond to
revised allegations about their eligibility marks.
Facts of the matter are :
Certain posts of Intermediate Trained Teacher (Classes I to V) were
advertised on 10th August, 20153 by the District Education
Superintendent, Dhanbad. The appellants applied for the post and
acquitted themselves successfully in the recruitment process. After
completion of the joining formalities, the appellants started
discharging their duties from December, 2015 as teachers.
On 27th September, 2016, show cause notices were issued to the appellants alleging that they did not fulfill the eligibility criterion of having secured a minimum of 45% marks in their intermediate examination (Class XII). Questions were also raised on the validity of their certificates of graduation.
In October 2016, through separate replies to the show cause notices, the appellants contended that being members of the Scheduled Tribe category, they were required to secure only 40% marks in the intermediate examination and not 45%. In other words, they were entitled to a relaxation of 5% marks in terms of the advertisement. It was further asserted that Ravi, Premlal and Surendra had secured 42.55%, 40.22%, and 41.33% marks, respectively, in the intermediate examination and, thus, were eligible for participation in the recruitment process. With respect to the issue concerning their graduation certificates, the appellants clarified that no graduation certificate was required for appointment on posts of teachers in Classes I-V, and that the same had been furnished by them only for the sake of completeness.
On 7th October, 2016, by separate office orders, the services of the appellants were terminated on the ground that they had secured less than 40% marks in the intermediate examination and that their certificates of graduation were not proper. According to the calculation made by the Department, Ravi, Premlal, and Surendra had secured 38.56%, 39.78%, and 39% marks, respectively in the intermediate examination. In arriving at this calculation, the Department excluded the additional marks secured by the appellants in the vocational subject.
Appellants challenged the termination orders dated 7th October, 2016, before the High Court by filing separate writ petitions. A Single Judge of the High Court allowed these petitions in the years 2018 and 2022 and, consequently, the impugned termination orders were set aside.
Aggrieved thereby, the respondents preferred intra-court appeals. As noted before, a Division Bench of the High Court allowed these appeals and dismissed the challenge laid by the appellants to the orders terminating their services.
Crestfallen by such determination, the appellants have invoked this Court's appellate jurisdiction.
The case arose from a 2015 recruitment drive for Intermediate
Trained Teachers (Classes I-V) in Jharkhand's Dhanbad district. The
appellants, all belonging to Scheduled Tribe communities, had been
appointed after clearing the selection process. However, their
services were abruptly terminated in 2016 on the grounds that they
had failed to secure the minimum required marks in their
intermediate examinations and that their graduation certificates
were invalid.
The Supreme Court, after detailed analysis, found that the teachers'
marks in vocational subjects-which were meant to improve their
overall percentage-had been wrongly excluded by the authorities. The
Court clarified that such exclusion was not permitted under the
rules governing eligibility for the Teacher Eligibility Test (TET).
The Bench observed:
"The respondents excluded the marks secured in the vocational
subjects without affording the appellants notice or an opportunity
to contest such exclusion... The termination orders stand vitiated
being in violation of the principles of natural justice."
The Court directed that Ravi Oraon and Premlal Hembrom be treated as
being in continuous service from December 2015, with full arrears of
pay and restoration of seniority. However, for the late Surendra
Munda, who passed away in August 2024, the Court ordered that his
heirs be paid all arrears of salary and be eligible for benefits
under any compassionate appointment scheme.
The judgment underscores the judiciary's stance on protecting
employees from administrative overreach and reaffirms that fairness
and due process are integral to government service decisions.
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