Authority: Orissa High Court, Cuttack

Order Date: 27 August 2026

Case Overview

  • Petitioner: Sri Banamali Sahoo, aged about 59, Section Officer (Level‑II) in the Office of the Dean, Research, OUAT, Bhubaneswar.
  • Opposite Parties: 1) Chancellor, OUAT; 2) Vice‑Chancellor, OUAT; 3) Commissioner‑cum‑Secretary, Dept. of Agriculture & Food Production, Govt. of Odisha; 4) Registrar, OUAT; 5) Ashirbad Satapathy, Placement Officer (later redesignated Skill Development Officer) at OUAT.
  • Nature of Proceeding: Writ petition under Articles 226 and 227 of the Constitution challenging two OUAT orders – Office Order dated 26‑12‑2015 appointing Ashirbad Satapathy as Placement Officer and Office Order dated 15‑12‑2020 rejecting the petitioner’s representations for the same post.
  • Background:
  • 1988‑1991: petitioner served as Research Fellow under ICRAR project; thereafter appointed as Field Investigator (pay Rs 3,200‑4,900) without meeting qualification.
  • 1999: High Court (O.J.C. 9987 of 1998) directed OUAT to consider petitioner for a suitable post when a vacancy arose and to condone his age.
  • 2000: Govt. of Odisha instructed compliance; petitioner appointed Junior Assistant (pay Rs 3,050‑4,590) on 03‑04‑2000, later promoted to Senior Assistant and Section Officer.
  • 2010: OUAT created a new non‑teaching post “Placement Officer (Class‑II)” by abolishing the Farm Superintendent post; Academic Council (Resolution 6504, 12‑08‑2010) and Board of Management (Resolution 3633, 22‑09‑2010) prescribed qualifications.
  • 18‑10‑2010: Advertisement issued for the Placement Officer post with essential qualification of a Bachelor’s degree plus an MBA/HRM etc.; last date of receipt 20‑11‑2010.
  • 2015: After the selection process, Ashirbad Satapathy was appointed (Office Order 29537, 26‑12‑2015) with pay scale Rs 15,600‑39,100 plus AGP Rs 6,000.
  • 2020: Petitioner filed multiple representations (01‑01‑2020, 02‑06‑2020, 28‑10‑2020, 13‑11‑2020, 01‑12‑2020) seeking appointment as Placement Officer at the scale Rs 9,300‑34,800 with GP Rs 4,600, as per Government Letter 10216 (20‑06‑2014). All were rejected by Office Order 17431‑E‑I‑II‑18/2009/UAT dated 15‑12‑2020.
  • Prior litigation: W.P.(C) 19653 of 2010 (dismissed 01‑09‑2015), W.A. 630 of 2015 (dismissed 18‑12‑2015), S.L.P.(C) 12760 of 2016 (dismissed 13‑05‑2016), Review Petition RVWPET 211 of 2016 (partial deletion of paragraph, disposed 19‑12‑2019). All rulings affirmed that petitioner lacked the requisite qualification.
  • Petitioner’s Contentions: The 2014 Government letter altered the qualification and pay scale; OUAT should have issued a corrigendum to the 2010 advertisement; the appointment of Satapathy is therefore illegal, arbitrary and unconstitutional; petitioner should be accommodated in the post retrospectively.
  • Opposite Parties’ Contentions: The advertisement’s qualifications are binding; the selection process was completed in accordance with the 2010 advertisement; the 2014 letter was merely advisory and could not change the criteria; the appointment of Satapathy is valid; the petition is barred by res judicata and the principle that eligibility criteria cannot be altered mid‑process.

Final Outcome

  • The Court held that the petitioner’s claim is devoid of merit. The earlier judgments (1999, 2000, 2015, 2019, 2020) establishing that the petitioner does not possess the essential qualification remain binding.
  • The appointment of Ashirbad Satapathy as Placement Officer (later Skill Development Officer) under Office Order 29537 dated 26‑12‑2015 is upheld.
  • The Office Order 17431 dated 15‑12‑2020 rejecting the petitioner’s 2020 representations is likewise upheld.
  • Consequently, the writ petition (W.P.(C) 18436 of 2021) is dismissed with no order as to costs.

Topics: Placement Officer appointment, Public service recruitment, Judicial review