Karnataka Validation Act: SC Bars Laws That Annul Judgments

🗞️ Why in News The Supreme Court on Thursday, 29 October 2026 struck down the Karnataka Civil Services (Validation of Selection and Appointment of 2011 Batch Gazetted Probationers) Act, 2022, holding it unconstitutional. A Bench of Justices J.B. Pardiwala and K. Vinod Chandran held that a legislature may remove the basis of a judgment but cannot annul a final judgment by law, and that appointments made under the Act will come to an end.

The case turns on one question every GS2 answer on separation of powers meets sooner or later: when a court has settled a dispute, can a legislature undo the result by passing a law? Karnataka tried, for a recruitment that its own government had cancelled and the courts had found tainted. The Supreme Court said no.

The 2011 Recruitment and How It Unravelled

On 3 November 2011 the Karnataka government notified recruitment to 362 posts of Group A and B officers through the Karnataka Public Service Commission (KPSC), under the Karnataka Recruitment of Gazetted Probationers (Appointment by Competitive Examinations) Rules, 1997.

What followed, as the judgment records it:

• 2013: on the Advocate General’s advice, the State withheld the final select list pending an inquiry by the State CID, which found “rampant corruption and instances of blatant nepotism of officials” of the KPSC. The State cancelled the entire recruitment.
• The courts: the selected candidates won before the Karnataka Administrative Tribunal (KAT), which quashed the government order, but Public Interest Litigations against the KAT’s order succeeded. The High Court affirmed the cancellation of the select list dated 21 March 2014, and the Supreme Court dismissed the challenge in Avinash C. and Ors. v. State of Karnataka.
• The findings it rested on: call details between candidates and KPSC members; identical interview marks “at least in the case of 566 candidates”; and a digital video recorder in the KPSC building that “was replaced to destroy the evidence”.
• A second attempt failed: a plea to resume the recruitment from the written examination results was rejected by the High Court, and the challenge to that also failed in the Supreme Court.

The 2022 Act: Overruling the Courts by Statute

Then, “after more than a decade from the stage of recruitment, when obviously the political currents kept on changing”, as the judgment puts it, the Validation Act was passed in 2022. It is Karnataka Act 14 of 2022: it received the Governor’s assent on 12 March 2022 and was first published in the Karnataka Gazette Extraordinary on 14 March 2022. It cites Entry 41 of List II (State List) of the Seventh Schedule.

Its section 3 opens: “Notwithstanding anything contained in any judgment, decrees or order of any court, Tribunal or Authority to the contrary”. It then declared the 2011 selection by the KPSC “valid in accordance with law”, cancelled the State’s orders of 15 October 2013 and 14 August 2014 withdrawing the recruitment, provided for appointment orders, and barred any suit or court order directing review of the appointments.

The Act’s Statement of Objects argued that “the decision of the High Court leads to violation of the Article 14 and 16 of Constitution of India”.

Under the Act, the judgment records, “out of the 362 candidates selected, 46 were found tainted. Appointment was given to 191 candidates out of which 14 are tainted.”

As background to the appeal, petitions against the Act went to the KAT and the High Court in March 2022. The High Court dismissed the writ petition by an order of 21 April 2022, which the Supreme Court called “cryptic”, and later upheld the KAT’s refusal of interim relief.

What the Supreme Court Held

The holding. “We have no doubt in our minds that the subject legislation is unconstitutional. We set aside the same, as also the judgments impugned herein, both in the PIL and the Writ Petition filed against the order of the KAT.” Justice K. Vinod Chandran wrote the judgment.

The principle. Relying on S.T. Sadiq v. State of Kerala (2015), the Court said that while validating a law retrospectively, notwithstanding a court’s decision, “it is permissible to alter the very basis of an earlier decision but cannot directly annul the final judgment by a subsequent legislation, which act of the legislature would be declared unconstitutional.” As LiveLaw summarised it, since the very basis of the judgment was not removed, the Act tends to annul the final judgment, which is impermissible.

Applied to Karnataka. The cancellation had been upheld by the High Court and the Supreme Court, so “the power does not lie with the legislature to annul the cancellation, even by a legislation and thus nullify the judgments of the Constitutional Courts.”

No equity for the selected. “There could be no equity, insofar as the selected candidates are concerned, especially the selection being based on a recruitment which is declared as tainted by the Constitutional Courts and the appointment having been effectuated based on a stillborn legislation; the Act of 2022.”

The State’s own stand. Appearing for Karnataka, Kapil Sibal “candidly submitted that the legislation cannot at all be supported”. The Act was defended by the selected candidates.

On the High Court. The Bench recorded “a little bit of surprise and a lot more alarm” at the High Court’s judgments, for “upholding an enactment clearly beyond the scope of the powers conferred on the law-making authority and bordering on the absurd.”

The judgment is marked non-reportable and comes from a two-judge Bench; its force lies in applying a settled line to a stark set of facts.

The Relief: Moulded, Not a Fresh Start

Having struck the Act down, the Court said “the appointments made pursuant to the tainted recruitment will also come to an end.” That includes those appointees not found tainted. Because of “the passage of a decade and a half”, it would not restart the 2011 selection from the stage at which it was found tainted. Instead:

• the State is to notify recruitment for the vacant Group A and B posts under the recruitment rules now in force;
• appointees not found tainted, the six appellants and the petitioners before the KAT get age relaxation as a one-time opportunity, competing with other eligible candidates;
• if selected, their seniority runs only from the date of appointment, with no back wages or notional appointment;
• those now in service who are selected again will have their earlier service counted for pension and retirement benefits.

Mains Lens: Legislatures, Courts and the Integrity of Recruitment

• Separation of powers. A legislature can change the law for everyone; it cannot sit in appeal over a decided case. Section 3’s “notwithstanding anything contained in any judgment” clause, with nothing done to cure the defect the courts had found, is the clearest kind of legislative overruling.
• Rule of law. In the words of the Cauvery reference the Court relied on, a State that can override judicial review by statute “would sound the death knell of rule of law”.
• The PSC’s integrity. The judgment, recounting the High Court’s findings, calls a Public Service Commission “a Constitutional Body meant to act in aid of efficient and smooth functioning of the administration by making recruitments without any taint thereat.” A validation law for a tainted selection rewards exactly the conduct the Commission exists to prevent.
• Equity and its limits. Candidates who were not tainted have served for years. The Court refused them equity in the post but softened the blow with age relaxation and pension credit: a balance between the rule of law and individual hardship.
• Delay. Fifteen years from notification to final word is itself a governance failure; the posts must now be filled again under today’s rules.

What comes next: the State Government is to notify recruitment for the vacant posts. The judgment sets no date for it.

Way Forward

• Fix the cause, not the verdict: if a legislature disagrees with a judgment, it must change the law’s basis prospectively or in general, not validate one tainted list.
• Make PSC recruitment tamper-evident: secure records, recorded interviews and independent audit of marks, so that findings like identical marks for 566 candidates cannot arise.
• Time-bound litigation: recruitment disputes should be settled within a recruitment cycle, not across a decade and a half.
• Accountability: the inquiry’s findings against officials call for disciplinary and criminal follow-through, not only cancellation.

For background on the constitutional frame of Public Service Commissions, see our 1 October deep dive on the UPSC at 100 and Articles 315 to 323.

UPSC Relevance

GS Paper 2: Separation of powers between organs; functioning of the judiciary and the legislature; constitutional bodies (State Public Service Commissions); services under the Union and the States.

Prelims: Articles 141, 309, 315 and 320; Entry 41 of List II; the doctrine on validating Acts; Article 14 and Article 16.

Mains: “A legislature may remove the basis of a judgment but cannot annul it. Examine this principle in the light of the Supreme Court’s decision on Karnataka’s 2022 Validation Act.” (250 words)

📌 Facts Corner, Knowledgepedia

Prelims, statement-ready facts:

• Struck down: Karnataka Civil Services (Validation of Selection and Appointment of 2011 Batch Gazetted Probationers) Act, 2022
• Karnataka Act 14 of 2022: Governor’s assent 12 March 2022; first published in the Gazette Extraordinary 14 March 2022
• The Act cites Entry 41 of List II (State List) of the Seventh Schedule
• Bench: Justices J.B. Pardiwala and K. Vinod Chandran; judgment by Justice Chandran; 29 October 2026
• Case: Srinivasa T. and Ors. v. State of Karnataka and Ors.; 2026 INSC 1173
• 2011 recruitment: notified 3 November 2011; 362 Group A and B posts; 1,38,307 applied
• Under the Act: 46 of 362 selected found tainted; 191 appointed, of whom 14 tainted
• Article 309: legislature regulates recruitment and conditions of service; Article 320: PSCs conduct examinations
• Article 315: a Public Service Commission for the Union and for each State
• Rule: a legislature may alter the basis of a judgment, not directly annul it (S.T. Sadiq v. State of Kerala, 2015)

Prelims, the traps:

• A two-judge Bench, marked non-reportable; not a Constitution Bench
• Not a fresh full selection and not reinstatement: appointments end; vacant posts to be re-notified
• Karnataka itself did not defend the Act in the Supreme Court; the selected candidates did

Mains, arguments and keywords:

• Keywords: validating Act, separation of powers, legislative overruling, rule of law, PSC integrity, moulded relief
• Frame: the legislature changes the law in general; the court decides the case; a law that only reverses a verdict fails

Interview, be ready for:

• “Is it fair to remove officers who were not tainted?” The selection itself was void; the Court eased the hardship with age relaxation and pension credit.

Sources: Supreme Court of India, Srinivasa T. and Ors. v. State of Karnataka and Ors., Civil Appeals arising out of SLP (C) Nos. 21195-21196 of 2023, judgment of 29 October 2026 (2026 INSC 1173). LiveLaw, Yash Mittal, 29 October 2026. The Hindu, “Top court axes Karnataka law validating ‘corrupt’ hiring”, Krishnadas Rajagopal, 30 October 2026 (print). Karnataka Act 14 of 2022 (Karnataka Gazette Extraordinary). Constitution of India (Legislative Department text, 2024).

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