DR. M. DAKSHAYANI v. THE STATE OF KARNATAKA INSC 364

Name of the case: Dr. M. Dakshayani v. The State of Karnataka

Year decided: 2018

Facts: Dr. M. Dakshayani and Dr. were both serving as Assistant Surgeons in Karnataka, with Dakshayani appointed in 1987 and Respondent No.2 in 1991. In 1992, Respondent No.2 was deputed as a Lecturer in the Health & Family Welfare Department without possessing a requisite postgraduate degree, a move that was supposed to be temporary and not confer any seniority. Later, both doctors were permitted to change their cadre to Lecturers, with Dakshayani's change effective in 1999 and Respondent No.2's in 2001 after obtaining the necessary qualifications. Subsequently, Respondent No.2 was promoted to Assistant Professor in 2001 and then to Professor in 2006, prompting Dakshayani to challenge these promotions before the Karnataka Administrative Tribunal.

Issue: The primary issue was whether the promotions granted to Respondent No.2 were valid, given the alleged procedural irregularities and the fact that Dakshayani, being senior, was overlooked.

Decision: The Supreme Court upheld the High Court's decision, which had reversed the Tribunal's order, thereby validating the promotions of Respondent No.2.

Majority Decision Reasoning: The Court acknowledged that while there were procedural lapses in the deputation and subsequent promotions of Respondent No.2, these were administrative decisions taken by the government. The Court emphasized that it would not interfere with such decisions unless there was a clear violation of statutory provisions or manifest injustice. It was noted that both doctors had been accommodated in the Medical Education Department, and the promotions were part of the administrative discretion exercised by the state.

Dissenting Opinion Reasoning: There was no dissenting opinion in this case; the judgment was unanimous.

Impact of the case: This case underscores the judiciary's reluctance to interfere in administrative decisions related to promotions and appointments unless there is a blatant violation of laws or principles of natural justice. It highlights the complexities involved in service matters within government departments and the importance of adhering to procedural norms to prevent disputes.