State of Mysore v. R.V. Bidap

The Supreme Court decided that when a member of a State Public Service Commission becomes its Chairman, he starts a fresh six-year term from the date of becoming Chairman. A Chairman is a distinct office though both posts are “members” under Article 316. The Court also said that if the statutory words are unclear, judges may look at external aids (mischief, object, social context, debates) as admissible but not decisive help.

• Does a member appointed as Chairman get a fresh six-year term from that date?
• May courts use external aids (object, mischief, debates, social context) to read a statute when the text is unclear?

• Article 316 tenure: Members hold office for six years; the Chairman is a separate office within the Commission.
• Fresh term on elevation: When a member becomes Chairman, the Chairman’s term runs anew from the date of that appointment.
• Articles 316 & 319 purpose: Preserve the independence and integrity of the Commission; prevent influence through reappointments or later government posts.
• External aids: If language is obscure, courts may consider the mischief, the object, the social context, and even debates/notes—admissible but not conclusive.

• The Court held for R.V. Bidap: the six-year term as Chairman runs from his appointment as Chairman (1969).
• Though Chairman and Member are both “members” under Article 316, the duties differ; the Chairmanship is a new and distinct office.
• Articles 316 & 319 aim to protect independence of the Commission, not to restrict a Chairman’s fresh term after elevation.
• External aids may be considered when text is unclear; they are admissible but not determinative.

The Chairman’s office is distinct. Elevation to Chairman triggers a new six-year tenure starting from the date of appointment as Chairman. The interpretive approach respects the purpose of Articles 316 and 319—to safeguard the Commission’s independence—while allowing careful, non-decisive use of external aids when the statutory language is obscure.

• Gives a clear tenure rule for PSC Chairmen after elevation.
• Protects the functional independence of Public Service Commissions.
• Offers a balanced method for using external aids in interpretation.
• Guides future disputes on office distinction and term calculation.

Mnemonic: C-F-E → Chairman, Fresh term, External aids.

1. Chairman: Different office from Member.
2. Fresh term: Six years from elevation.
3. External aids: Use when text is unclear; not conclusive.

Issue: How to count the Chairman’s tenure when a Member is elevated; whether external aids may be used.

Rule: Article 316 provides a six-year term; Chairmanship is a distinct office; external aids are admissible if language is unclear.

Application: Elevation in 1969 made Bidap Chairman; a new six-year term begins then. Purpose of Articles 316/319 supports independence. External aids confirm the scheme.

Conclusion: Fresh six-year Chairman term from 1969; external aids are permissible but not determinative.

Article 316

Fixes appointment and six-year tenure for PSC members and Chairman.

Article 319

Limits reappointment and later government posts to keep the Commission independent.

External Aids

Materials like object, mischief, debates, and context used when wording is unclear.

• State of Bombay v. R.M.D. Chamarbaugwala — purpose-based reading and mischief rule.
• Samsher Singh v. State of Punjab — constitutional offices and independence themes.
• R.K. Jain v. Union of India — tribunals and independence considerations.