The Delhi High Court has refused to interfere with the rejection of a Scheduled Tribe candidate’s application for the post of Prosecutor in the Serious Fraud Investigation Office (SFIO). The court held that eligibility must be judged strictly on the basis of details submitted before the cut-off date and that courts cannot rewrite recruitment conditions.
A Division Bench of Justice Anil Kshetrapal and Justice Amit Mahajan dismissed the writ petition filed by Anant Kumar Rao, challenging the decision of the Union Public Service Commission (UPSC) and the order of the Central Administrative Tribunal (CAT).
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Background of the Case
The dispute arose from Advertisement No. 18/2022 issued by UPSC inviting applications for 12 posts of Prosecutor in SFIO under the Ministry of Corporate Affairs.
As per the advertisement, candidates with a five-year integrated law degree were required to have two years of experience in handling litigation, court matters, or administration of law in a government organisation.
Anant Kumar Rao applied for the post, claiming experience at Willard Advisory Pvt. Ltd. from March 2020 to October 13, 2022 - the last date for submission of applications. He stated that he had over two years of experience.
However, UPSC rejected his candidature, citing lack of the required experience in handling litigation or court matters in a government organisation. The Commission also refused to consider additional experience certificates submitted after the cut-off date.
Rao approached CAT, which dismissed his application. He then moved the High Court under Article 226 of the Constitution.
Petitioner’s Arguments
Appearing for the petitioner, counsel argued that Rao belonged to the Scheduled Tribe category and should have been granted relaxation under the notes appended to the advertisement.
It was also submitted that the experience gained at Willard Advisory involved legal drafting and criminal matters, and should have been treated as sufficient. The petitioner further contended that the post did not necessarily require court appearances and that any omission in the Online Recruitment Application (ORA) was bona fide.
Court’s Observations
The bench carefully examined the duties mentioned in the recruitment notice. These included assisting in filing prosecutions before courts, coordinating with government counsel, and maintaining records of court cases.
The court noted that the petitioner had claimed experience only in a private company at the time of filing the ORA. The nature of duties disclosed related mainly to drafting contracts, compliance work, and corporate documentation.
“The experience disclosed by the petitioner pertained predominantly to drafting and vetting of commercial contracts and corporate legal work,” the bench observed.
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Significantly, the court recorded that during the proceedings before the Tribunal, the petitioner did not assert that he had made court appearances or handled litigation in the manner required by the advertisement.
On the issue of additional documents submitted later, the court was firm. It observed that eligibility must be assessed on the basis of what was claimed and substantiated before the cut-off date.
Permitting candidates to supplement eligibility after the closing date, the court said, would “introduce uncertainty and inequality into the selection process.”
Reliance on Supreme Court Precedent
The bench relied on the Supreme Court’s judgment in Bedanga Talukdar v. Saifudaullah Khan.
Quoting from the ruling, the High Court noted that selection processes must be conducted strictly according to the terms of the advertisement.
“There cannot be any relaxation in the terms and conditions of the advertisement unless such a power is specifically reserved,” the Supreme Court had held.
The High Court emphasised that even where a relaxation clause exists, it does not give an automatic right to a candidate. It remains a discretionary power of the recruiting agency.
On Relaxation for ST Candidates
Addressing the argument based on the petitioner’s Scheduled Tribe status, the bench clarified that the relaxation clause did not create an enforceable right.
“Such a provision does not vest an enforceable right in any candidate to claim relaxation as a matter of course,” the court said.
It further held that no material was placed on record to show that UPSC’s refusal to exercise discretion was arbitrary.
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Decision
After examining the record and the Tribunal’s findings, the court concluded that the decision taken by UPSC was neither arbitrary nor illegal.
The bench held that the Tribunal had adopted a “plausible and consistent” view and that there was no ground for interference under writ jurisdiction.
Accordingly, the writ petition was dismissed, and all pending applications were disposed of.
Case Title: Anant Kumar Rao v. Union Public Service Commission & Ors.
Case No.: W.P.(C) 15303/2025
Decision Date: 13 February 2026
