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The Additional Chief Secretary To ... vs A Kathirvel
2026 Latest Caselaw 1223 Mad

Citation : 2026 Latest Caselaw 1223 Mad
Judgement Date : 13 March, 2026

[Cites 12, Cited by 0]

Madras High Court

The Additional Chief Secretary To ... vs A Kathirvel on 13 March, 2026

Author: G.K.Ilanthiraiyan
Bench: G.K.Ilanthiraiyan
                                                                                Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026
                                  IN THE HIGH COURT OF JUDICATURE AT MADRAS

                                              RESERVED ON : 12.03.2026

                                            PRONOUNCED ON : 13.03.2026

                                                            CORAM

                             THE HONOURABLE MR. JUSTICE G.K.ILANTHIRAIYAN

                                   Review Application(W) Nos.17, 25 to 30 & 58 of 2026

                Rev.Appl.(W)No.17 of 2026:-

                1. The Additional Chief Secretary to Government
                   Home Police III Department, Secretariat, St.
                   George Fort, Chennai-600 009.

                2. The Director General of Police
                   Mylapore, Chennai.

                                                                                                     ..Petitioner(s)
                                                                 Vs
                 1. A Kathirvel
                    Home Police III Department, Secretariat, St.
                    George Fort, Chennai-600 009.

                 2. N Hemamala
                    D/o.K.B.Nehru, No.234, Shanthi lllam,Ram
                    Nagar 6th Street,S.S.Colony, Madurai-16

                 3. K. Murugeswari
                    D/o. M. Krishnan, B2, Vaijanthi visthana
                    enclave, Vilangudi, Madurai-18

                 4. A. Bama
                    D/o. Venkataraman, No.15A, Rathanapuram,
                    Jaihindpuram 2nd street, Madurai-11



                Page 1 of 22


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                                                                          Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026




                 5. M. Shanthi
                    D/o. K. Muthusamy, No. 4635, Villapuram
                    housing board, Madurai

                 6. P.K. Regina
                    D/o. Murugesan, G3, 157, Comfort apartment,
                    Kurinji nagar, Athikulam, Madurai-14

                 7. M. Chezhian
                    S/o. Movendran, No.31, TNHB quarters,
                    Pothigai nagar, Madurai-18

                 8. D. Saravanakumar
                    S/o. P. Dhavamani, No.58, Viswanatha nagar,
                    K.Pudur, Madurai-7

                 9. S. Kowsalya
                    D/o. V. Subbaiah, No. 18, Adi Eswara nagar,
                    Ponmeni garden, Uthangudi, Madurai

                 10.K. Mariappan
                    S/o. R. Kanmani, No.13/2949-3, North 1st
                    street, Adthmasamy nagar, Pathinamkathen,
                    Ramanathapuram, Ramanathapuram (DT)

                 11.S.R.G. Thayal
                    Inspector Of Police, Kannagi Nagar Police
                    Station, Tambaram Commissionerate,
                    Tambaram.

                 12.C. Muthelu
                    Inspector Of Police, Modern Control Room,
                    Chennai.

                 13.S. Saravanan
                    Inspector Of Police, Shankar Nagar Police
                    Station, Tambaram Commissionerate,
                    Tambaram.

                Page 2 of 22


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                                                                            Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026




                 14.K. Pugalendhi
                    Inspector Of Police, Sivakasi Town Police
                    Station, Virudhunagar District

                 15.K. Kottaiswamy
                    Inspector Of Police, Keeraithurai (l And O)
                    Madurai City, Madurai.

                 16.Chandru
                    Inspector Of Police, Selaiyur Police Station,
                    Tambaram Commissionerate, Tambaram.

                 17.Deepak Kumar
                    Inspector Of Police, Pallikaranai Crime,
                    Tambaram Commissionerate, Tambaram.

                 18.M. Saravanan,
                    Inspector of Police, Achirupakkam Police
                    Station, Chengalpattu District.

                 19.V.J. Muthukumar,
                    Inspector of Police, Mathuranthagam Police
                    Station, Chengalpattu District.

                 20.S. Kumaran,
                    Inspector of Police, ACTU, Kancheepuram
                    District.

                 21.3 Alexandar,
                    SP Inspector, Chengalpattu District.

                 22.Senthilvelkumar,
                    Inspector of Police, Earaniel Police Station,
                    Kanyakumari District.

                 23.Anantharajan,
                    Inspector of Police, AIG, L and O Office, Chief
                    Office, Chennai.

                Page 3 of 22


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                                                                                   Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026


                 24.S. Rajesh Kannan,
                    Inspector Of Police, Special Intelligence Unit,
                    Sbcid, Ramanathapuram.

                 25.S. Senthilvel Kumar,
                    Inspector Of Police, Eraniel Police Station,
                    Kanyakumari District.

                 26.S. Ramesh Kannan,
                    Inspector Of Police, Civil Supplies Cid,
                    Pollachi Unit, Coimbatore District.

                 27.V. Balamurugan,
                    Inspector Of Police, Thoothukudi North Police
                    Station, Thoothukudi.

                 28.R. Mathavan,
                    Inspector Of Police, Sankarankovil Taluk
                    Police Station, Tenkasi District.

                                                                                                     ..Respondent(s)

                Prayer : Petition filed under Order XLVII Rule-1 r/w Section 114 of Code of
                Civil Procedure, to review the order dated 20.11.2025 made in W.P.
                (MD)No.22457 of 2024


                                  For Petitioner          : Mr.J.Ravindran
                                                            Additional Advocate General
                                                            Assisted by Ms.M.Sneha
                                                            Special Counsel

                                  For Respondents
                                  For R1 to 10, 12,
                                  14, 16 to 28      : No appearance
                                  For R11, 13 & 15 : Mrs.A.L.Ganthimathi, Senior Counsel
                                                      For Mr.L.Palanimuthu


                Page 4 of 22


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                                                                               Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026
                                                 COMMON ORDER

These Review Applications have been filed to review the order

dated 20.11.2025, passed by this Court in a batch of Writ Petitions in

W.P.Nos.28009, 28105, 28630, 28716, 30969 of 2024 & W.P(MD).Nos.22388,

22457 of 2024, thereby setting aside the impugned proceeding dated 29.08.2024

and the combined seniority list dated 12.09.2024.

2. The Writ Petitions have been filed challenging the order passed by

the Review Applicants dated 29.08.2024, thereby stating that orders have

already been issued in G.O.Ms.No.556, Home (Police-III) Department dated

31.12.2020 in which, the Director General of Police was directed to revise the

seniority of the directly recruited Sub Inspectors of Police during the year 1997-

1998 as per the marks obtained by them in the Police Training College and to

prepare a fresh seniority list in a combined manner by clubbing the candidates

sent for training in two different batches as one batch, is perfectly valid in the

eye of law and will stand the test of law. This Court issued direction on the basis

of the order passed by the Hon’ble Supreme Court of India in the case of

Ranjith Singh and other Vs. The State of Tamil Nadu in S.L.P(c)No.5137 &

5138 of 2021 by an order dated 01.05.2025, as follows :-

“9. Considering the above facts and circumstances, this Court is inclined to pass the following directions:-

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

(i) In view of the order passed by the Hon'ble Supreme Court of India, the impugned proceedings dated 29.08.2024 and the combined seniority list dated 12.09.2024 are hereby set aside.

(ii) The respondents 1 & 2 are directed to revise the seniority list as directed by the Hon'ble Supreme Court of India by an order dated 01.05.2025 in S.LP(C)No.5137 and 5138 of 2021.

(iii) The respondents 1 & 2 are directed to treat the direct recruitees for the year 1997-98 as two batches viz., first batch of the year 1999 and the second batch of the year 2000.

(iv) It is made clear that seniority of the candidates shall be fixed based on their marks secured in examination conducted by the Tamil Nadu Uniform Service Recruitment Board.” To review the said order, the present Review Applications have been filed by the

Review Applicants.

3. The learned Additional Advocate General appearing for the Review

Applicants submits that the direction issued in sub clause (iii) in paragraph 9 of

the order is contrary to the direction issued in sub clause (ii) & (iv). Therefore,

there is an error apparent on the face of records and it shall be reviewed. He also

raised the ground that the selection for the post of Sub Inspector of Police was

made in two phases for the year 1997-98 batch and the candidates were sent for

training in two batches viz., one in the year 1999 and another in the year 2000.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 Those candidates were selected in zone wise selection through the same

examination under the very same notification on the same day but, they were

sent for training in two batches due to administrative exigencies in conducting

training to all the selected candidates. 50% of the selected candidates in each

category in each zone were sent for training in first batch commenced from

16.04.1999 and the remaining persons were sent for training in second batch

commenced from 22.05.2000. If the seniority of the directly recruited Sub

Inspectors of Police for the year 1997-98 is prepared batch wise, in pursuance to

the order passed by this Court, it would amount to contempt of the order passed

by the Hon’ble Supreme Court of India in the case of Ranjith Singh and others

Vs. The State of Tamil Nadu. The Hon’ble Supreme Court of India held that

since the candidates were selected from single examination, they shall be treated

as a single unit only and they cannot be separated into two batches. Therefore,

the concept of fixing seniority based on batch wise becomes infructuous.

4. Per contra, Mr.M.A.Gouthaman, learned counsel appearing for

some of the respondents in Rev.Appln(W).No.25 of 2026 filed counter and

submitted that the review applications itself are not maintainable as there is no

error apparent in the order passed by this Court. Therefore, there is no ground to

review the order passed by this Court. It would amount to re-appreciation of

facts and it cannot be done by way of review. If at all there is any grievance

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 over the order passed by this Court, the applicants can file an appeal. He further

submits that the first batch of Sub Inspectors of Police were sent for training on

16.04.1999 based on their meritorious marks, which means the classification of

the two batches itself was based on the marks secured by the candidates in the

qualifying examination. Therefore, this Court rightly issued direction to treat the

direct recruitees for the year 1997-1998 as two batches viz., first batch of the

year 1999 and the second batch of the year 2000. Now the Review Applicants

want to have one seniority list which was actually challenged before this Court

in the batch of Writ Petitions, as the first batch of highest marks scorers were

sent for training on 16.04.1999 and the second batch was sent to training after a

lapse of more than one year i.e., on 22.05.2000. Therefore, the Applicants

cannot blow hot and cold at the same time.

4.1. He further submitted that even assuming that there should be one

seniority list for both the batches, again the highest scorers of the first batch will

always be above the second batch. It does not make any difference and

therefore, the considered ground in the Writ Petitions and the settled law cannot

be reargued and reviewed. The fulcrum of the matter is about treating two

different batches based on the marks secured and the date of joining duty and

upon considering all the submissions, this Court has passed a reasoned order.

Even according to the Review Applicants, the candidates who secured higher

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 marks were sent for training in the first batch and those candidates who secured

lesser marks than the first batch candidates were sent for training in the second

batch. Therefore, this Court rightly directed the Director General of Police to

prepare seniority list treating the two batches separately and it doesn’t warrant

any review once again.

5. Mr.R.John Joseph, learned counsel appearing for some of the

respondents in Rev.Appln(W).No.25 of 2026 filed counter and submitted that as

directed by the Hon’ble Supreme Court of India, the seniority must be fixed

solely on the basis of the marks obtained by the candidates in the qualifying

examination during the selection process. In fact, some of them filed

Miscellaneous Petitions before the Hon’ble Supreme Court of India in in M.P.

Diary Nos.49489 & 54019 of 2025 in S.L.P.(c) No.5137 & 5138 of 2021

seeking clarification. These petitions were dismissed by the Hon’ble Supreme

Court of India by an order dated 26.09.2025, by observing that those

applications are seeking a substantive modification of the judgment and it is not

permissible in the miscellaneous application. It was further held that judicial

verdicts are not like sand dunes which are subject to the vagaries of wind and

weather. A disturbing trend has emerged in this Court where repeated

miscellaneous or review applications are being filed after the pronouncement of

a final judgment. Such a practice has no legal foundation and must be firmly

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 discouraged. Therefore, the present review also has been filed in the same

manner to modify the order passed by this Court. There is absolutely no error

apparent on the face of record and as such the order passed by this Court cannot

be reviewed in any angle.

6. Mr.A.M.M.Ramana, learned counsel appearing for the respondents

in Rev.Appl(W)No.29 of 2026 filed counter and submitted that, based on the

order passed by this Court, the Government issued order in G.O.Ms.No.93 dated

06.02.2012 restoring the seniority in the 1999 batch with refixation of seniority

based on the marks secured by them in the selection process. Consequently, the

Director General of Police issued proceedings dated 08.10.2016 thereby fixing

the seniority in the post of Sub Inspector of Police by including their names in

the appropriate place in the 1999 batch. Thereafter, they were given promotion

to the post of Inspector of Police. Even according to the Review Applicants, the

selected Sub Inspector of Police were sent for training based on their marks

secured in the selection process. Therefore, this Court rightly passed order and it

doesn’t require any review.

7. Heard the learned counsel appearing on either side and perused the

materials placed before this Court.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

7. Mr.M.A.Gouthaman, learned counsel appearing for some of the

respondents in Rev.Appln(W).No.25 of 2026, relied upon a judgment of the

Hon’ble Supreme Court of India in the case of Northern India Caterers (India)

Ltd vs Lt. Governor Of Delhi reported in 1980 (2) SCC 167 and the relevant

portions of the said judgment are extracted hereunder:

“8. It is well settled that a party is not entitled to seek a review of a judgment delivered by this Court merely for the purpose of a rehearing and a fresh decision of the case. The normal principle is that a judgment pronounced by the Court is final, and departure from that principle is justified only when circumstances of a substantial and compelling character make it necessary to do so. Sajjan Singh v. State of Rajasthan.For instance, if the attention of the Court is not drawn to a material statutory provision during the original hearing, the Court will review its judgment. G. L. Gupta v. D. N. Mehta.The Court may also reopen its judgment if a manifest wrong has been done and it is necessary to pass an order to do full and effective justice. O. N. Mahindroo v. Distt. Judge Delhi &Anr.Power to review its judgments has been conferred on the Supreme Court by Art. 137 of the Constitution, and that power is subject to the provisions of any law made by Parliament or the rules made under Art.

145. In a civil proceeding, an application for review is entertained only on a ground mentioned in XLVII rule 1 of the Code of Civil Procedure, and in a criminal proceeding on the ground of an error apparent on the face of the record. (Order

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 XL rule 1, Supreme Court Rules, 1966). But whatever the nature of the proceeding, it is beyond dispute that a review proceeding cannot be equated with the original hearing of the case, and the finality of the judgment delivered by the Court will not be reconsidered except "where a glaring omission or patent mistake or like grave error has crept in earlier by judicial fallibility." Sow Chandra Kanta v. Sheikh Habib.

9. Now, besides the fact that most of the legal material so assiduously collected and placed before us by the learned Additional Solicitor General, who has now been entrusted to appear for the respondent, was never brought to our attention when the appeals were heard, we may also examine whether the judgment suffers from an error apparent on the face of the record. Such an error exists if of two or more views canvassed on the point it is possible to hold that the controversy can be said to admit of only one of them. If the view adopted by the Court in the original judgment is a possible view having regard to what the record states, it is difficult to hold that there is an error apparent on the face of the record.”

8. Citing the said judgment, learned Counsel contended that the

review application itself is not maintainable as there is no error apparent in the

order passed by this Court. This argument cannot be countenanced to and the

judgment cited supra shall not be squarely applicable to the case on hand for the

reason that though this Court by an order dated 20.11.2025, issued the above

said directions in a batch of Writ Petitions directing the Review Applicants to

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 treat the direct recruitees for the year 1997-1998 as two batches viz., first batch

of the year 1999 and the second batch of the year 2000, it is an error on the face

of records as it would lead to the contempt of the order of the Hon’ble Supreme

Court in the case of Ranjith Singh and others Vs. The State of Tamil Nadu and

hence it is liable to be reviewed as rightly pointed out by the Review Applicants.

9. Further, based on the judgment passed by the Hon’ble Supreme

Court of India, dated 01.05.2025, the Government passed ordered in

G.O.Ms.No.556 Home (Police-III) Department dated 31.12.2020, thereby

directing the Tamil Nadu Uniformed Services Recruitment Board to recast all

gradation list issued from the year 1995 in respect of direct recruitment which

includes 20% in-service candidates recruited directly to the post of Sub

Inspector of Police for granting seniority on the basis of the marks obtained in

the qualifying examination and to send the same to the Director General of

Police. On receipt of the revised mark list, the Director General of Police was

directed to implement the order passed by the Hon’ble Supreme Court of India.

10. It is pertinent to mention here that those who were not selected in

the recruitment process in the year 1997-1998 for the post of Sub Inspector of

Police, challenged the said selection process before the Tamil Nadu

Administrative Tribunal, Chennai, in a batch of Applications, on the ground that

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 the selection was made zone-wise under the same notification. Therefore, the

non-selected candidates, who secured even higher marks than the selected

candidate but in different zone, are also eligible to the post of Sub Inspector of

Police. Therefore, the zone-wise selection is in violation of Articles 14 and 16 of

the Constitution of India. The Tribunal by an order dated 19.07.2001, held that

selection to the post of Sub Inspector of Police has to be made by a single

method for the entire State. There is no such rule of zone-wise selection wherein

each zone is considered as a separate unit and the merits of the candidates of a

particular zone alone is considered. It was further observed that most of the

applicants have secured higher marks than some of the persons selected from

other ranges. Therefore, ends of justice will be met, if the applicants are also

given appointment. Finally, those who have secured more marks than the

selected candidates were allowed to participate in the selection process for the

post of the Sub Inspector of Police.

11. It was challenged before this Court and the Hon’ble Division

Bench of this Court in a batch of Writ Petition in W.P.No.17639 of 2001 etc., by

an order dated 25.02.2004 held as follows :-

“73. In such circumstances, we pass the following order:

i) The Selection of both of Sub-Inspectors of Police (Men and Women) pursuant to the selection made for the vacancies notified for the year 1997-98 by resorting to zone-wise selection

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 was invalid inasmuch as such zone-wise selection was impermissible under Special Rules governed for Tamil Nadu Police Sub-ordinate Service.

ii) Having regard to the fact that such selection and appointment came to be made as early as far back as in the year 1999, at this distant point of time, applying the ratio of the Honble Supreme Court referred to in earlier paragraphs (i.e.para 61 to 64), we are not inclined to set aside the said selection.

iii) Even as regards the 53 candidates with reference to whom the Directorate of Vigilance and Anti-corruption has submitted its final report holding that their selection was tainted with mal-practices, we hold that while their appointments cannot be set aside at the present juncture, their continuation in service will depend upon the final outcome of the criminal proceedings pursuant to the final report dated 18-6-2004.

iv) The concerned 53 persons should be informed about our orders relating to them by a specific notice to be issued to them.

v) While modifying the order of the Tribunal, we hold that from amongst the applicants who are the contesting respondents both Men and Women covered by W.P.Nos.17639 to 17660 of 2001, 17822 to 17827, 17830, 17899 to 17903 and 18349 to 18356 of 2003, such of those contesting respondents who have secured the lowest cut off marks in the category, namely, OC, BC, MBC, SC and ST after the interview, should be directed to undergo medical test and after following the usual formality of police verification about their antecedents, and in the event of

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 those contesting respondents ultimately, coming out successful, should be placed on probation and sent for police training which should be followed by their appointment and regularization as per the prescribed regulations.

vi) Such of the contesting respondents who were not called for interview, shall be called for interview and after coming out successful in the interview, if their cut off marks is more than the last cut off marks in the respective category, they shall be directed to undergo medical test and after following the usual formality of police verification about their antecedents, and in the event of those contesting respondents ultimately, coming out successful, should be placed on probation and sent for police training which should be followed by their appointment and regularization as per the prescribed regulations.

vii) The above said direction will also hold good in respect of the applicants who have filed O.A.Nos.10211 and 10324 of 1998, 1354, 4693 and 6796 of 1999, 955, 4212, 5668, 5669, 5671, 6659 and 8616 of 200 0, 2557, 6301 and 6746 of 2001, 1920, 2189, 2286, 2424, 3073, 3633, 3 745, 3751, 3999, 4194, 5001, 5142, 5518, 5546, 5687, 5688, 6412, 6429 , 6458 and 6459 of 2002 and 18, 19, 129,330, 388, 389, 796, 2130 of 2

viii) The other Original Applications, namely, O.A.Nos.

2579, 2715, 3 864, 3929, 3930, 4084 of 2003 and 26, 78, 207, 1625 and 1626 of 2004 as well as W.P.Nos.32253, 32255, 32499, 33155, 33136, 22344, 22015, 2 3063 and 34275 of 2004 are dismissed on the ground of delay and laches.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

ix) The petitioners-State Government are directed to take steps against the concerned Officers in accordance with the Tamil Nadu Pension Rules, based on the outcome of the criminal proceedings.

x) We direct the petitioners to follow the above said directions and complete the above said exercise and issue appropriate orders as regards the final outcome within four weeks from the date of receipt of copy of this order.”

12. Thus, it is clear that the selection of both batches of Sub Inspector

of Police by resorting zone-wise selection was declared as invalid. However, the

Hon’ble Division Bench of this Court declined to set aside the entire selection

and directed the candidates who were not called for interview to participate in

the selection process. If they fulfill other requirements, it was also directed that

they may be selected for the post of Sub Inspector of Police. Thus, it is clear

that those applicants had secured more marks than the candidates who were

selected in different zone. Therefore, the Tribunal as well as the Hon’ble

Division Bench of this Court declared that the zone wise selection is invalid and

those candidates who secured more marks than the selected candidates can be

selected in due process. Accordingly, they were selected for the post of Sub

Inspector of Police.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

13. The learned Additional Advocate General appearing for the Review

Applicants relied upon the judgment reported in (2015) 14 SCC 221 in the case

of A.Raghu Vs. Government of Andhra Pradesh & ors., in which the Hon’ble

Supreme Court of India held as follows :-

“26. From the factual position depicted herein above, it is not possible for us to accept, that the candidates, who were deputed for training on 15.7.1991, and those deputed for training on 14.6.1992 to fulfill the deficiency, can be described as two different batches. The selection process having been joint, and in furtherance of the same notification dated 22.1.1991 (issued by the Recruitment Board), it is inevitable for us to conclude, that the candidates deputed to the two different courses of training (on 15.7.1991 and 14.6.1992) were essentially candidates belonging to a singular batch, who were selected through a common process of selection. In fact, the instant inference, insofar as the issue of inter-se seniority is concerned, is inevitable, as the dates on which the candidates were deputed for training, are inconsequential, so far as Rule 15 is concerned.”

14. He also relied upon the judgment of the Hon’ble Division Bench of

this Court in the case of M.P.Saraswathy & ors Vs. R.Paranthaman & ors in

W.A.No.732 of 2022 dated 08.11.2023, as follows :-

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026 “15. We have considered all the materials and the contentions relevant to the issue under determination. The contention of the appellants that the selection being range wise and hence, it is not a single selection process, is not acceptable. The notification was for selection of 10000 Grade-II Constables and the appointment subsequent thereto was by a joint process. The division of the candidates on range/district wise for administrative exigencies will not alter the nature of the selection process or the applicability of the rule to which the selectees have subjected themselves to. Further, as per Rule 37 of the TNSPSS, which deals with the Area of Service, a member of service shall be liable to serve in any part of the State of Tamil Nadu or when so ordered by the state government in any part of the India, outside such State. Therefore, the contention that selection was range wise has no significance, more so when it comes to fixation of seniority. A candidate is sent for training after the selection. There is no rule which states that the candidates with higher marks in the initial selection will be sent for training first. The marks secured by them in the selection is not a yardstick to divide the candidates into different categories for sending to training. As per Rule 24 (d), for the purpose of fixing the seniority, the marks secured by them at the Recruitment School alone is relevant, while so, it is not for the State to create an artificial division by picking and choosing the candidates for training based on the marks scored by them in the selection. Once the candidates are part of same notification and selection, the date on which they are sent for training is irrelevant…...”

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

15. In the cases on hand, the Sub Inspector of Police who were selected

under the very same notification of the year 1997-1998 by zone wise and

subsequently the range/zone wise selection was also set aside by the Tamil Nadu

Administrative Tribunal and the same was also confirmed by the Division

Bench of this Court and they were sent for training by two batches. Therefore,

the above judgments are squarely applicable to the present cases. Thus, the

selection of Sub Inspector of Police under the very same notification by

range/zone wise has no significance, when it comes to fixation of seniority.

Further, there is no rule while states that the candidates with higher marks will

be sent for training first. The mark secured by the candidates is not a yardstick

to divide them into different categories for sending them to training.

16. In view of the above discussions, the direction issued by this Court

by an order dated 20.11.2025, in the paragraph No.9 sub clause (iii) alone is

reviewed and the following direction is issued in lieu of the same:-

(iii) the Review Applicants are directed to prepare a combined seniority list for the candidates who were recruited to the post of Sub Inspector of Police for the year 1997-1998 considering them as a single batch irrespective of the fact that they were sent for training as two different batches in the year 1999 and 2000.

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm ) Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026

17. Accordingly, the order dated 20.11.2025, passed by this Court in a

batch of Writ Petitions in W.P.Nos.28009 of 2024 etc., is reviewed and all the

Review Applications (W) are disposed of. There shall be no order as to cost.





                                                                                                          13.03.2026
                                                                                                             (1/3)
                Index            : Yes/No
                Neutral Citation : Yes/No
                Speaking/Non Speaking order

                Note : Registry is directed to
                      incorporate cause title for all
                      the cases and issue order copy.
                rts







https://www.mhc.tn.gov.in/judis                ( Uploaded on: 13/03/2026 07:48:16 pm )
                                                                     Rev.Appln(W).Nos.17, 25 to 30 & 58 of 2026



                                                                         G.K.ILANTHIRAIYAN, J.
                                                                                                           rts




                                                                          Common order

in Review Application(W) Nos.17, 25 to 36 & 58 of 2026

13.03.2026 (1/3)

https://www.mhc.tn.gov.in/judis ( Uploaded on: 13/03/2026 07:48:16 pm )

 
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