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Madras High Court· 20 July 2026

Under Article 142 of the Constitution of India, do Supreme Court directions in a service matter bind authorities even without a direct challenge to the unamended rule?

2. M.R.Manjula Inspector of Police Inservice Training Centre St. Thomas Mount Alandur, Chennai-600016 v. R. Ranjith Singh
2026:MHC:3069 · WA No. 927 of 2026
Coram: Justice S.M.Subramaniam · Justice N.Senthilkumar
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Answer

Yes — once review and clarification petitions against the Supreme Court's directions stand dismissed, the judgment becomes the law of the land under Article 142 and must be followed by the authorities concerned, and absence of a challenge to the first proviso does not permit its continued application in violation of that judgment.

Headnote

Tamil Nadu Special Rules for Police Subordinate Service — First proviso to Rule 25(a) — Constitution of India — Article 142 — Seniority of directly recruited Sub Inspectors of Police — Selection marks versus training marks — Binding effect of Supreme Court directions — Tamil Nadu Special Rules for Police Subordinate Service, First proviso to Rule 25(a) — Effect of Supreme Court directions on rule providing for training marks — Held: The first proviso to Rule 25(a), which contemplated fixation of seniority of directly recruited Sub Inspectors on the basis of marks obtained in the final training examination, loses its relevance once the Supreme Court has directed that seniority be fixed solely on marks obtained in the selection process; the Government must re-frame Rule 25 to conform to that dictum. (¶10) Selection process versus police training — Distinction between selection marks and training marks for seniority — Held further: Selection and training are two distinct stages — appointment orders are issued on the basis of the merit rank in the select list published by the Uniformed Services Recruitment Board, and training marks obtained thereafter during the probation period are relevant only to confirmation of service, not to fixation of seniority. (¶9, 10) Constitution of India, 1950 — Article 142 — Binding nature of Supreme Court directions as law of the land — Held further: A direction issued by the Supreme Court in exercise of its jurisdiction, once the review and clarification applications against it stand dismissed, becomes the law of the land under Article 142 of the Constitution of India and must be followed by the authorities concerned notwithstanding the absence of a direct challenge to the unamended proviso. (¶10) Intra-court appeal — Maintainability — Scope of writ order under review — Held further: Where the review order limits itself to directing preparation of a combined seniority list for a specific recruitment batch without disturbing the core direction to fix seniority on selection marks, no infirmity arises in the writ order impugned; the Writ Appeal is dismissed with no order as to costs. (¶11)

In the Court's own words
Paragraph 10After issuance of appointment order, the appointed candidates are sent for police training. Training period is probation period and on successful completion of probation period the services are confirmed. Unsatisfactory performance during the probation period may result in terminating the services. Therefore, selection and training are two different aspects. On completion of selection, the selected candidates are appointed. The marks awarded during the probation period will be taken into consideration for issuance of confirmation/regularisation of services, but it is in no way connected with the marks obtained by the respective candidates during the selection process conducted by USRB. Challenge not made against the First Proviso to Rule 25(a) of Tamil Nadu State Police Subordinate Service Rules is not a ground to violate the judgment of the Hon’ble Supreme Court of India. Clarification sought for by Government in this regard was dismissed by the Apex Court. Therefore, it is for the Government to re-frame and amend Rule 25 as per the dictum laid down by Hon’ble Supreme Court in Ranjith Singh’s case (cited supra). In view of the above factual position and based on the directions issued by the Hon’ble Supreme Court in Ranjith Singh’s case, the proviso clause relied on by the appellants lost its relevance and the judgment of the Hon’ble Supreme Court of India becomes the law of the land under Article 142 of the Constitution of India and is to be followed by the authorities concerned.
Acts & Sections
First proviso to Rule 25(a) of the Tamil Nadu Special Rules for Police Subordinate ServiceArticle 142 of the Constitution of IndiaArticle 14 of the Constitution of IndiaArticle 16 of the Constitution of IndiaArticle 21 of the Constitution of India

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Also decided in this judgment
Does the first proviso to Rule 25(a) of the Tamil Nadu Police Subordinate Service Rules survive where the Supreme Court has directed seniority be fixed on selection marks?For fixing seniority of directly recruited Sub Inspectors, are selection marks or subsequent training marks to be considered?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections