Gajula Thirupathi v. Telangana State Level Police Recruitment Board & Ors., 2026

The appellant, Gajula Thirupathi, had been provisionally selected for appointment as a Stipendiary Cadet Trainee Police Constable (SCTPC) in Telangana.

His candidature was subsequently cancelled by the Telangana State Level Police Recruitment Board because of his previous involvement in a criminal case.

The criminal case had been registered under Sections 417, 420 and 506 read with Section 34 IPC.

The case originated from allegations made by a woman who was the appellant's neighbour.

According to the allegations, the appellant and the woman had been in a relationship for several years on the understanding that they would marry.

The relationship ultimately did not culminate in marriage because the appellant subsequently married another woman.

The criminal case was eventually compounded before a Lok Adalat in 2015.

Importantly, the appellant had disclosed the criminal case in his attestation form. There was therefore no allegation that he had suppressed or concealed a material fact from the recruitment authorities.

Despite the disclosure, the Recruitment Board treated the criminal case as involving moral turpitude and concluded that the appellant was unsuitable for appointment to the police force.

The appellant challenged the cancellation of his candidature before the Telangana High Court.

A Single Judge of the High Court directed reconsideration of his appointment.

The matter was subsequently considered by the Division Bench, which upheld the Recruitment Board's decision.

The appellant therefore approached the Supreme Court.

The Supreme Court examined whether the authorities were justified in treating the appellant's past relationship and the resulting criminal case as demonstrating poor moral character or moral turpitude.

The Supreme Court allowed the appeal filed by Gajula Thirupathi.

The Court set aside the judgment of the High Court Division Bench which had upheld cancellation of the appellant's candidature.

The Court restored the order of the High Court Single Judge directing reconsideration of the appellant's appointment.

The Supreme Court held that an employer is entitled to examine the suitability of a candidate even where a criminal case has ended in acquittal, discharge or compromise.

However, such an assessment cannot be arbitrary and must be based upon relevant material.

The authorities must have material demonstrating both that an offence involving moral turpitude was committed and that the candidate was involved in that offence.

In the present case, the appellant and the complainant were both adults and neighbours and had remained in a relationship for approximately four years.

The Court noted that there was no allegation of rape and no material suggesting that the compromise before the Lok Adalat had been obtained through threat, coercion or inducement.

The Court rejected the Recruitment Board's assumption that the compromise itself amounted to an admission of guilt.

The Supreme Court described that assumption as being without basis and completely perverse in the circumstances of the case.

The Court emphasised that a relationship between two consenting unmarried adults is not prohibited by law merely because the relationship is premarital.

The Court further observed that not every relationship culminates in marriage.

Therefore, the mere fact that a relationship ended without marriage cannot automatically establish that one party cheated the other.

The Court held that whether a person was actually deceived into entering a relationship would ordinarily require consideration of the complainant's allegations and evidence.

In the present case, the complainant had ultimately chosen not to pursue the allegations and had agreed to compound the case.

The Court distinguished cases involving allegations of violence and public disorder, where compromise and acquittal may not necessarily eliminate concerns regarding suitability for a disciplined force.

The present case, according to the Court, concerned a private relationship between consenting adults, and the circumstances did not provide sufficient basis for treating the appellant as morally unsuitable for police employment.

The Screening Committee's decision was therefore held to be arbitrary.

The appellant was consequently entitled to the relief granted by the High Court Single Judge.

Suitability is different from automatic disqualification: The judgment recognises that recruitment to a police force involves scrutiny of character and suitability. However, the power to assess suitability does not permit authorities to treat every past criminal allegation as an automatic bar to employment.

Evidence must support moral-turpitude finding: The central principle is that an adverse conclusion regarding moral character must have a factual foundation. Merely pointing to the existence of a criminal case was insufficient in the circumstances before the Court.

Failed relationship is not synonymous with cheating: The Court made an important distinction between a relationship that ultimately fails and a relationship entered into through deception. The fact that marriage did not occur does not, without more, establish that the original promise was dishonest.

Importance of consent: The Court's reasoning was particularly focused on the fact that the parties were consenting adults. It rejected the proposition that the existence of a consensual premarital relationship itself could be used as evidence of poor character.

Compromise cannot automatically equal guilt: The Recruitment Board's reasoning that the Lok Adalat compromise amounted to an admission of guilt was rejected. A compromise has to be assessed according to its actual circumstances and cannot mechanically be treated as proof that the accused committed the alleged offence.

Disclosure by the candidate: The appellant had disclosed the criminal case in his attestation form. This meant that the case did not involve concealment or false disclosure, which can constitute an independent consideration in recruitment cases.

Contemporary social realities: The judgment expressly recognises changing social circumstances. The Court cautioned authorities against applying assumptions about marriage and relationships that do not necessarily reflect contemporary social realities.

Distinction from violent offences: The Court carefully distinguished cases concerning violence, public disorder or other conduct directly demonstrating unsuitability for a disciplined force. The present matter involved a private relationship between adults and lacked those additional features.

Limits of administrative discretion: Recruitment authorities possess discretion in evaluating suitability, but that discretion must be exercised rationally and on relevant considerations. An assumption unsupported by evidence can render the decision arbitrary.

Significance for police recruitment: The judgment is particularly relevant because the appellant was seeking appointment to a police force. The Court did not hold that police recruitment authorities cannot consider past criminal conduct. Instead, it held that such consideration must be fact-specific and evidence-based.

Fact-specific nature of the ruling: The decision should not be understood to mean that every criminal case arising from a relationship will be irrelevant to police recruitment. The Court's conclusion depended upon the particular circumstances, including the consensual nature of the relationship, absence of rape allegations, absence of coercion in the compromise, disclosure of the case and lack of sufficient material establishing moral turpitude.