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Issues Involved:
1. Whether the High Court could issue a writ of mandamus directing a public authority to exercise its discretion in a particular manner. 2. Whether the Comptroller and Auditor-General of India properly exercised the discretion conferred by the Office Memorandum dated January 21, 1977, regarding relaxation of qualifying standards for Scheduled Castes and Scheduled Tribes candidates in the SAS Examination. Summary: Issue 1: Writ of Mandamus The first contention was whether the High Court could issue a writ of mandamus directing a public authority to exercise its discretion in a particular manner. The Supreme Court clarified that the High Court had not issued a writ of mandamus but had issued directions under Article 226 of the Constitution. The Court emphasized that under Article 226, High Courts have the power to issue directions, orders, or writs to enforce Fundamental Rights or for any other purpose. The judgment cited several precedents to illustrate that the High Courts can issue such directions where the government or public authority has failed to exercise or has wrongly exercised discretion conferred upon it by a statute, rule, or policy decision. Issue 2: Exercise of Discretion by Comptroller and Auditor-General The second issue was whether the Comptroller and Auditor-General of India had properly exercised the discretion conferred by the Office Memorandum dated January 21, 1977. The judgment analyzed the relevant provisions of the Constitution, Office Memoranda, and the Comptroller and Auditor-General's Manual of Standing Orders. It was found that the Comptroller and Auditor-General had not applied the relevant factors required by the Office Memorandum dated January 21, 1977, and the relaxation given was arbitrary and insufficient. The Court held that the relaxation should have been fixed in advance and notified to the candidates, taking into account the number of reserved vacancies and the overall strength of the cadre. Conclusion: The Supreme Court dismissed the appeal, confirming the judgment of the Division Bench of the Madras High Court. The Court substituted the High Court's order with a directive that for the Part II SAS Examination and subsequent examinations until the date of the judgment, there would be a relaxation of 25 marks for Scheduled Castes and Scheduled Tribes candidates. The respondents and other similarly situated candidates were declared to have passed the examinations and promoted with effect from the date of the final declaration of results. The Court also directed the Comptroller and Auditor-General to fix and notify a relaxed or lower standard in advance for future examinations. The appellants were ordered to pay costs of Rs. 1,500 to each respondent. The Court expressed appreciation for the assistance provided by Mr. V.A. Bobde, Advocate, who appeared as amicus curiae.
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