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

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    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
    
    
    
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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.
    
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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.
    
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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
    
    
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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

    SPONSORED

    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:-

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    (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.

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    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
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    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
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    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
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    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.

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    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
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    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
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    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
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    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
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    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
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    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
    003.

    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.

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    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.

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    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 :-

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    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……”
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    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.

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    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
    
    
    
    
                    Page 21 of 22
    
    
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                                                                         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)

    Page 22 of 22

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