The Supreme Court ruled that bias cannot be inferred if alleged relatives of appointees did not participate in the selection process. The case involved Shiksha Karmis, whose 1998 appointments were canceled by the Madhya Pradesh High Court due to their relationship with selection committee members. A split verdict from Justices JK Maheshwari and KV Viswanathan led to a three-judge bench review.
The Court emphasized that courts should not interfere with expert body selections unless bias, malafides, or statutory violations are proven. It found no reasonable likelihood of bias since the recusal resolution ensured that relatives did not influence the process. The doctrine of necessity was cited, acknowledging that conflicts of interest may be unavoidable in smaller jurisdictions.
The Court also ruled that the principles of natural justice were violated as the affected candidates were not given a fair hearing before their selection was canceled. It held that an ineffective hearing at the initial stage taints the entire process, making the cancellation invalid.
Upholding Justice Viswanathan’s view, the Court quashed the High Court’s decision, allowing the appeals. Given the appellants' 25 years of service, it declined to remand the matter for reconsideration.
