ISSUE:
Whether the application of Section 3 of the Public Employment (Requirement as to Residence) Act, 1957, by the State of Andhra Pradesh in the context of recruitment to public employment violates the principles enshrined under Article 16 of the Constitution of India, which guarantees equality of opportunity in matters of public employment without discrimination on grounds of residence?
Whether the restriction imposed by Section 3 of the Public Employment Act, 1957, requiring a candidate to be a resident of the State of Andhra Pradesh for a specified period as a condition for eligibility for certain public employment positions, is consistent with the constitutional mandate of Article 16 and its underlying principles of equality and non-discrimination?
RULE:
Equality of Opportunity in Public Employment: The court emphasised the principle of equal opportunity for all citizens in matters of public employment. This is a fundamental right, ensuring that no one is discriminated against based on residence, except in very limited circumstances allowed by law.
Narrow Construction of Exceptions to Equality: The court applied a narrow interpretation of the exception in Article 16(3), which allows Parliament to prescribe residential qualifications for public employment. The court clarified that this exception should only apply to the entire state and not to specific parts or regions within a state.
Supremacy of the Constitution: The court reinforced that Parliament's powers are derived from the Constitution, and even when making laws under Article 16(3), Parliament must act within the constitutional framework and cannot extend beyond its prescribed limits.
Non-Discrimination Based on Residence: The court reiterated that the Constitution prohibits discrimination in public employment based on residence, and any law or rule must strictly comply with this principle, barring the limited exceptions allowed by Article 16(3).