Supreme Court Holds That Admission to a Training Course Does Not Create a Right to Government Appointment and Legitimate Expectation Cannot Override Changed Recruitment Policy

Case Name: State of Uttar Pradesh & Ors. v. Bhawana Mishra & Ors. (connected matters)
Citation: 2026 INSC 38
Date of Judgment/Order: 08 January 2026
Bench: Justice Rajesh Bindal and Justice Manmohan

Held: The Supreme Court held that admission to and completion of the Ayurvedic Nursing Training Course does not create any vested or enforceable right to appointment as an Ayurvedic Staff Nurse, and the doctrine of legitimate expectation cannot be invoked to compel the State to follow an outdated recruitment practice when there has been a clear and rational change in policy, selection process, and statutory framework governing appointments.

Summary: The appeals arose from directions issued by the Allahabad High Court requiring the State of Uttar Pradesh to consider candidates trained in Ayurvedic Nursing for appointment based on past practice. The respondents relied on decades-old practice where trainees from a single government institution were routinely appointed after training and claimed legitimate expectation. The Supreme Court examined the evolution of policy, including the 2011 decision permitting private institutions to impart training, the exponential increase in trained candidates, the 2014 notification bringing recruitment within the purview of the Uttar Pradesh Subordinate Services Selection Commission, and the eventual framing of statutory service rules in 2021. The Court analysed the advertisement conditions, bond requirements, absence of any promise of appointment, and constitutional limits of legitimate expectation, and found that changed circumstances justified a merit-based selection process applicable uniformly to all eligible candidates.

Decision: The appeals were allowed, the judgments of the High Court directing consideration of the respondents for appointment were set aside, and it was held that the respondents have no automatic or preferential right to appointment, with recruitment required to be conducted strictly in accordance with prevailing statutory rules and selection procedures, and all pending applications disposed of.