A notice dated June 21, 2026 has issued by the Registrar General of the Patna High Court by order of the Court, stating that the judicial officers whose candidature along with other judicial officers was rejected vide notice dated June 21, 2019 taking notice of the order dated May 10, 2019 of the Supreme Court in Dheeraj Mor vs. Hon'ble High Court of Delhi, Special Leave to Appeal (C) No. 14156/2015 with W.P. (C) No. 414/2016 (X)] are selected for interview under the District Judge (Entry Level), Direct from Bar Exam-2019 in terms of the 23-page long order dated March 11, 2026 passed by 3-Judge Bench of Chief Justice Surya Kant, Justice Joymalya Bagchi and Justice Vipul M. Pancholi of the Supreme Court of India in Civil Appeal No. 3947 of 2020 (Rejanish K.V. vs. K. Deepa & Ors.) and other connected cases and 6-page long order dated May 22, 2026 passed by the same 3-Judge Bench of the Supreme Court in Dheeraj Mor vs. Hon’Ble High Court of Delhi &Ors. Miscellaneous Application No. 1249 of 2026 in Review Petition (Civil) No. 621 of 2021 in Civil Appeal No. 1698 of 2020 as well as upon consideration of their respective representations. The March 11, 2026 order was passed in terms of the 139-page long judgement dated October 9, 2025 in 2025 SCC OnLine SC 2196 by the Supreme Court's 5-Judge Constitution Bench of Justice B.R. Gavai, Chief Justice of India and Justices Aravind Kumar, Satish Chandra Sharma, K. Vinod Chandran, and M.M. Sundresh.
In its order dated May 22, 2026, the 3-Judge Bench of the Supreme Court observed: "3. On a bare reading of paragraph 170, there is no doubt that the judgment has to be effected prospectively, w.e.f. 09.10.2025. The Bench, however, carved out an exception in favour of those where “any selection process [was] completed, or any appointment [was] made prior to this judgment...”. In other words, if a direct recruit or even a serving judicial officer, who had been permitted to participate in the selection process, and had been selected or appointed, all such selections and appointments have been protected. Such selected officers are entitled to appointment and if such appointed officers were relieved on the ground of eligibility, they are also entitled to seek reinstatement. However, in terms of paragraph 170, reproduced above, it is clear that on the basis of selection which would be contingent on the outcome of an incomplete selection process and a anticipated consequential appointment, no relief of deemed seniority can be granted. This principle has also been given shape to in our order dated 11.03.2026." It concluded: "4. All the High Courts are, accordingly, directed to review the individual cases of the judicial officers and take an appropriate decision in terms of the law laid down by the Constitution Bench." The Court was referred to paragraph 170 of the judgement dated October 9, 2025 by the 5-Judge Constitution Bench.
In its order dated March 11, 2026, the Supreme Court's 3-Judge Bench has concluded:"22. For the purposes of cadre management, we deem it apposite to issue a final clarification: all the judicial officers, who would benefit from deemed service from the original date of appointment or a retrospective notional date due to the judgment passed by the Constitution Bench and the instant final order, shall be taken to be District Judges appointed through direct recruitment. 23. In the interest of complete fairness, we acknowledge that, in the course of oral submissions, various other related issues have been raised by learned senior counsel/counsel for the parties. However, in the absence of specific pleadings with reference to each High Court and the factual determinations that would be required to be made for adjudication thereon, we are afraid that it would not be prudent for this Court to go into those questions at this stage. The same are, accordingly, kept open for the parties to agitate, at the first instance, before the Committee of Judges described above. The Committee shall decide the factual disputes and submit its recommendation to the Full Court of the High Court. The Full Court shall, in turn, take the final decision, within four months of the aggrieved party having submitted its representation. There shall, however, be an endeavour by each High Court to not generate new inter-se seniority disputes, especially given that members of the bar have given up their practice to join the Higher Judicial Services with a legitimate expectation of seniority based upon the date of their appointment. 24. In any case, the parties shall be at liberty to raise such contention(s), if need be, in appropriate judicial proceedings."
This order has been passed in terms of the 139-page long judgement dated October 9, 2025. The judgement was delivered upon hearing following substantial questions of law for consideration of a Constitution Bench: (i) Whether a judicial officer who has already completed seven years in Bar being recruited for subordinate judicial services would be entitled for appointment as Additional District Judge against the Bar vacancy? (ii) Whether the eligibility for appointment as a District Judge is to be seen only at the time of appointment or at the time of application or both? (iii) Whether there is any eligibility prescribed for a person already in the judicial service of the Union or State under Article 233(2) of the Constitution of India for being appointed as District Judge? (iv) Whether a person who has been Civil Judge for a period of seven years or has been an Advocate and Civil Judge for a combined period of seven years or more than seven years would be eligible for appointment as District Judge under Article 233 of the Constitution of India? A 3-Judge Bench of the Supreme Court in a batch of matters, by its order dated August 12, 2025, had referred the first two questions to the Constitution Bench. The Constitution Bench added last two questions for consideration and determination.
The Constitution Bench judgment dated October 9, 2025 conclusively answered the question of law and held that judicial officers are eligible for being appointed as District Judges through direct recruitment, and their past period of service as a judicial officer shall count towards the minimum practice requirement for such eligibility. In doing so, the Constitution Bench has overruled a previous three-judge bench decision of the Supreme Court in Dheeraj Mor vs. High Court of Delhi, (2020) 7 SCC 401. The Constitution Bench, through paragraph 175 of its judgment, directed that these cases be placed before an appropriate bench for final adjudication. Notably, paragraphs 170 to 174 of the judgment dated October 9, 2025 contains guiding directions for giving effect to the decision of the Supreme Court. These paragraphs are as under:
"170. In any case, we clarify that what we have held in this judgment will be applicable only from the date of this judgment and in no case, any selection process completed, or any appointment made prior to this judgment would be affected, except in cases wherein any interim order(s) were passed by the High Courts or this Court. In such cases, the issue would now be governed by the orders to be passed by the Bench hearing the matters.
F. CONCLUSION AND DIRECTIONS
171. In view of the answer which we propose to give for Question No. 4, it may not be necessary to deal with the other questions, however, since the questions are framed by this Court, we propose to answer all the questions.
172. In the result, we answer the questions as under:
(i) Judicial Officers who have already completed seven years in Bar before they were recruited in the subordinate judicial service would be entitled for being appointed as a District Judge/Additional District Judge in the selection process for the post of District Judges in the direct recruitment process;
(ii) The eligibility for appointment as a District Judge/Additional District Judge is to be seen at the time of application;
(iii) Though there is no eligibility prescribed under Article 233(2) for a person already in judicial service of the Union or of the State for being appointed as District Judge, in order to provide a level playing field, we direct that a candidate applying as an in-service candidate should have seven years’ combined experience as a Judicial Officer and an advocate;
(iv) A person who has been or who is in judicial service and has a combined experience of seven years or more as an advocate or a Judicial Officer would be eligible for being considered and appointed as a District Judge/Additional District Judge under Article 233 of the Constitution;
(v) In order to ensure level playing field, we further direct that the minimum age for being considered and appointed as a District Judge/Additional District Judge for both advocates and Judicial Officers would be 35 years of age as on the date of application.
(vi) It is held that the view taken in the judgments of this Court right from Satya Narain Singh (supra) till Dheeraj Mor (supra), which take a view contrary to what has been held hereinabove do not lay down the correct proposition of law.
173. The reference is answered accordingly.
174. Consequently, all such rules framed by the State Governments in consultation with the High Courts which are not in accordance with the aforesaid answers shall stand quashed and set aside. It is directed that all the State Governments in consultation with the High Courts shall frame/amend the rules in accordance with what has been held by us hereinabove, within a period of three months from today.
175. The Registry is directed to obtain the necessary orders from Hon’ble the Chief Justice of India, on the administrative side, to place the matters part of the present batch before an appropriate bench for deciding the same in the light of what has been held hereinabove."
It was in this context that the 3-Judge Bench of the Supreme Court passed the order dated March 11, 2026. Subsequent to these directions of the 3-Judge Bench of the Supreme Court, the notice dated September 2, 2026 of the High Court was published on its website on September 3, 2026.
The names of these six selected judicial officers are: Sanjay Kumar (Roll No. 10297), Ranjeeta Kumari (Roll No.12098), Upendra Sah (Roll No.12249), Priya Shekhar (Roll No.12763), Avinash Kumar (Roll No.12917) and Mohamm ad Ruknuddin (Roll No.13222).
The notice states that the notice dated June 21, 2019 has been modified to include the names of these judicial officers. The information regarding the date of the interview will be given soon . The candidatures of these selected candidates for interview are provisional. The High Court is free to decide about their eligibility at any stage upon proper verification. These candidates have been advised to be ready with their original documents/testimonials as detailed in the Advertisement so that they can upload the scanned copies of the same for the first stage verification at a short notice when the website/portal of the High Court shall be opened for the purpose. The candidates have also been advised to keep visiting the website of the Court regularly for further details and updates in the matter.
Notably, the Main (Written) Examination was held on May 12, 2019 in which 131 candidates, out of 140 candidates to whom admit cards were issued, had appeared. Its result was issued by a notice dated June 21, 2019 issued by the Registrar General by the order of the High Court which reads: "The candidature of the in-service candidates employed as Judicial officers, who appeared in the Main (written) Examination, has been rejected taking notice of the order dated 10.05.2019 of the Hon'ble Supreme Court in the case of Dheeraj Mor Vs. Hon'ble High Court of Delhi, Special Leave to Appeal (c) No. 14156/2015 with W.P. (C) No. 414/2016 (X), whereby it has been held that no new appointments be made from now onwards of in-service candidates against quota reserved for Bar and further held that in case even if in-service candidate has been selected in the examination held earlier as against the Bar quota no further appointment to be made of such candidates." Notably, 34 candidates who were selected for interview are:
1 Nalini Ranjan Srivastava (Roll No. 10104 )
2 Neeraj Sharma (Roll No. 10124)
3 Madhu Agrawal (Roll No. 10304)
4 Shailendra Kumar (Roll No. 10381)
5 Shailendra Kumar (Roll No. 10404)
6 Amit Awasthi (Roll No. 10560)
7 Brajesh Kumar (Roll No. 10700)
8 Kumar Saket (Roll No. 10778)
9 Brajesh Kumar Singh (Roll No. 10813)
10 Nikitha R Vora (Roll No. 10830)
11 Neelam Goswami (Roll No. 10983)
12 Sunita Rani Tiwari (Roll No. 10986)
13 Protima Parihar (Roll No. 11401)
14 Namrata Agrawal (Roll No. 11441)
15 Neeraj Madhup (Roll No. 11622)
16 Vinay Tewari (Roll No. 11649)
17 Ravishankar Kumar (Roll No. 11758)
18 Meetu Singh (Roll No. 11899)
19 Lakhwinder Singh Sood (Roll No. 11996)
20 Randhir Kumar Dhiraj (Roll No. 12254)
21 Naween Kumar (Roll No. 12312)
22 Manoj Kumar Tiwari (Roll No. 12691)
23 Binod Kumar (Roll No. 12808)
24 Arvind Kumar Sudhanshu (Roll No. 12904)
25 Mukund Kumar (Roll No. 13164)
26 Suman Kumar Divakar (Roll No. 13202)
27 Shiv Kumar (Roll No. 13208)
28 Achyut Jee (Roll No. 13279)
29 Rupesh Kumar (Roll No. 13359)
30 Seema Bhartiya (Roll No. 13429)
31 Dushyant Kumar (Roll No. 13457)
32 Anil Kumar Chandel (Roll No. 13609 )
33 Anil Kumar (Roll No. 13621)
34 Pushpa Kumari (Roll No. 13654)
The notice noted that "The aforesaid result has been prepared on the basis of provisions as contained in Advertisement no. BSJS/1/2019, The Bihar Superior Judicial Service Rules, 1951, letter number 588 dated 17.01.2017 issued by the General Administration Department, Govt. of Bihar to the Patna High Court and other authorities and also communication made to the Court by the State Government vide memo no. 12033 dated 18.09.2017 regarding roster formula applicable in respect of reserved Category candidates."
It also noted that "As per clause 11 of the Appendix- `C' to The Bihar Superior Judicial Service Rules, 1951, the qualifying marks for viva-voce test is 45% in each theory paper and as per clause 8 of the Appendix- `C' to the said Rules, there is provision of relaxation of 5% in qualifying marks in each theory paper for the reserved category candidates, including women candidates. 3. Amongst 34 candidates selected for the interview, there are 24 candidates, including 9 female candidates, in UR Category against 8 vacancies; 4 candidates in EBC Category against 3 vacancies; 6 Candidates in BC Category against 2 vacancies. No candidate could qualify in SC Category against 3 vacancies. The required number of SC (male / female or both), EBC (male / female or both) candidates could not obtain the minimum qualifying marks of 40% marks in each theory paper, therefore, the number of the selected candidates is less than the
required number which is three times the number of vacancies. Further, no candidate under BC/EBC (Female) category could obtain qualifying marks."
By a notice dated June 26, 2019 issued by Registrar General (I/c) by the order of the High Court stated that the candidates were selected for interview under District Judge (Entry Level), Direct from Bar Exam- 2019, their interview (Viva-Voce Test) was held on July 13, 2019 and July 14, 2019 in the premises of the High Court from 8.30 AM on wards. The candidates downloaded their interview letters from the website of the Court from July 1, 2019.
For the first stage verification, they were required to upload the scanned copies of their documents in the sequence, as indicated below:-
a) Matriculation certificate / Mark sheet showing date of birth.
b) Intermediate or equivalent Certificate
c) Graduation Certificate
d) LL.B. Certificate
e) Enrollment certificate of Bar Council
f) Certificate showing practice as an advocate / professional experience for not less than seven years as on 19.02.2019 issued by the competent authority as specified in the advertisement.
g) Declaration of net income for the last three financial years preceding the year of application i.e. 2018-19
h) Declaration regarding appearance in 24 cases per year in the last three years preceding the year of advertisement which is 2018-19.
The website of the Court was opened during June 28, 2019-July 4, 2019 for this purpose. The candidates coming for the interview were required to bring the originals of the scanned copies of the documents which they uploaded on the website of the Court. Failure to produce the original documents would disqualify them from appearing at the interview. In terms of Clause 3 of the advertisement dated January 19, 2019, the cutoff date for calculating the age of a candidate is January 1, 2019 and in terms of Clause 4 of the said advertisement, the cut off date for the purpose of consideration of other eligibility criteria was February 19, 2019. Candidates were requested to visit the Patna High Court website for further updates.
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