Primacy of merit-based open competition over past absorption conventions.

When the number of qualified candidates seeking public appointment far exceeds the number of sanctioned vacancies, the normal and constitutionally compliant rule dictates that appointments must be made through a competitive selection process based on relative merit. Broad-based open recruitment ensures that the State selects the best available talent to serve the public, fulfilling the overarching constitutional goals of administrative efficiency and equal opportunity in public employment under Articles 14 and 16. Past administrative conventions or historical practices of absorbing trainees without competitive screening, developed during periods of acute personnel scarcity, cannot be perpetuated once a competitive market emerges. The State is fully entitled, and indeed constitutionally obligated, to abandon informal absorption practices in favor of structured examinations conducted by public recruitment commissions to select qualified candidates based on open competition. (State of Uttar Pradesh and Ors. Vs Bhawana Mishra | 2026 INSC 38).