Leelavathi N. & Ors. v. State of Karnataka & Ors. – Supreme Court on Maintainability of Writ Petitions and Jurisdiction of Administrative Tribunals
Case Name: Leelavathi N. & Ors. v. State of Karnataka & Ors.
Citation: Civil Appeal Nos. arising out of SLP (Civil) Nos. 27984–27988 of 2023 & connected appeals
Date of Judgment/Order: 16 October 2025
Bench: Hon’ble Mr. Justice Vijay Bishnoi and Hon’ble Mr. Justice J.K. Maheshwari
Held: The Supreme Court of India held that service-related recruitment disputes fall squarely within the jurisdiction of the State Administrative Tribunal (KSAT) under the Administrative Tribunals Act, 1985, and that the High Court cannot be approached directly under Article 226 unless exceptional circumstances exist. The Court found that the Single Judge of the Karnataka High Court erred in entertaining writ petitions against the recruitment process for Graduate Primary Teachers when an effective statutory remedy before the Tribunal was available.
The Court dismissed all appeals and affirmed the Division Bench’s decision, directing the Karnataka State Administrative Tribunal (KSAT) to adjudicate the matter within six months.
Summary: The case concerned the 2022 recruitment of 15,000 Graduate Primary Teachers in Karnataka. Several married women candidates were denied OBC-category benefits because they had submitted caste-cum-income certificates of their fathers instead of husbands. A Single Judge of the High Court accepted their plea and directed that parental income should be considered.
On appeal, the Division Bench set aside the order, holding that the KSAT was the proper forum to challenge service-related decisions under the Administrative Tribunals Act, 1985. The Bench also ordered interim appointments for eligible candidates pending further proceedings.
The Supreme Court upheld the Division Bench’s ruling, emphasizing that the doctrine of alternate remedy is central to administrative adjudication. The High Court’s reliance on T.K. Rangarajan v. State of Tamil Nadu (2003) was deemed misplaced since that case involved a unique situation of mass dismissals.
Citing L. Chandra Kumar v. Union of India (1997 3 SCC 261), Rajeev Kumar v. Hemraj Singh Chauhan (2010 4 SCC 554), and Nivedita Sharma v. COAI (2011 14 SCC 337), the Court reiterated that High Courts must ordinarily decline to entertain service-related writ petitions where specialized tribunals are in place.
Decision: The Supreme Court dismissed all appeals, affirming that the Karnataka State Administrative Tribunal (KSAT) has exclusive jurisdiction under Section 15 of the Administrative Tribunals Act, 1985, to adjudicate recruitment and service-related disputes. It held that the writ petitions before the High Court were not maintainable, as the petitioners had an effective statutory remedy available before the Tribunal. The Court further clarified that inclusion of names in a provisional select list dated 18.11.2022 did not confer any vested right to appointment. Directing that the KSAT dispose of the pending applications within a period of six months, the Court also ordered that the interim protections earlier granted on 03.01.2024, 22.01.2024, and 04.10.2024 would continue to operate, with 500 posts to remain reserved pending final adjudication. In doing so, the Supreme Court reaffirmed the principle of judicial discipline and efficiency in administrative adjudication.