The Supreme Court has dismissed appeals filed by candidates for the Rajasthan Civil Judge posts who were denied selection for submitting their caste certificates after the specified cut-off date.
A three-judge bench comprising Justices Abhay S. Oka, Ahsanuddin Amanullah, and A.G. Masih upheld the decision of the Rajasthan High Court, stating that the candidates’ plea had no legal basis.
“The Subsequent Notice issued by the Rajasthan High Court on 04.08.2022 was lawful. It clearly required that caste/category certificates must be issued on or before 31.08.2021 — the last date of application. The advertisement had set this as the eligibility deadline,” the bench observed.
The Court explained that the requirement aligned with the original advertisement and related rules. The Supreme Court emphasized that no relaxation could be granted, and the appellants’ claims were not sustainable under law. The judgment further added that there was no discretionary clause in the rules that would allow exceptions in such cases.
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Background of the Case
The appellants had applied for posts in the Rajasthan Judicial Services under the reserved category. They successfully cleared both the preliminary and main examinations. However, they were not called for the interview stage because their OBC-NCL/MBC-NCL certificates were issued after the cut-off date.
Although the advertisement did not clearly mention the date for the issuance of category certificates, a Subsequent Notice issued later required candidates to submit:
- A valid certificate issued within one year prior to 31.08.2021,
OR - A certificate issued between 31.08.2018 and 30.08.2020, along with an affidavit confirming their category status.
The candidates argued that the advertisement didn’t specify any such date initially and hence, the new requirement was unfair and arbitrary. They claimed that they had valid certificates since 2016, which should have been accepted.
However, the Rajasthan High Court had already dismissed their plea, stating that OBC-NCL status is reviewed annually, and a fresh certificate is necessary to prove current eligibility.
The High Court referred to the Supreme Court’s earlier ruling in Ashok Kumar Sonkar v. Union of India, where it was held that when no date is mentioned, the application deadline becomes the effective cut-off.
The Supreme Court, while analyzing the case, noted that:
- The advertisement required candidates to possess all eligibility documents as per rules and instructions.
- Even though the advertisement didn’t mention the exact date for certificate issuance, paragraphs 6 and 18 made it clear that certificates should be in line with government rules.
- As per existing instructions, certificates are valid for one year, and extendable up to three years with an affidavit.
“The claim of reserved category status must hold true as on the last date of application. None of the appellants had valid certificates or supporting affidavits at that time,” the Court ruled.
Thus, the candidates’ claims were rejected on the basis of non-compliance with the rules stated in the advertisement and its subsequent notice.
Earlier in May 2023, the matter had gone before a two-judge bench of Justices Ajay Rastogi and Bela M. Trivedi, which led to a split verdict:
- Justice Ajay Rastogi believed that justice could be done under Article 142 of the Constitution, and the appellants deserved a chance based on their merit.
- Justice Bela M. Trivedi disagreed, stating that late submission of certificates made the candidates ineligible and they should not get preferential treatment.
“The appellants were defaulters. Accepting their delayed certificates would be unfair to other candidates who followed the rules,” Justice Trivedi had said.
Because of this disagreement, the case was referred to the current three-judge bench, which unanimously ruled against the appellants.
Case Title: SAKSHI ARHA Versus THE RAJASTHAN HIGH COURT AND ORS., C.A. No. 3957/2023 (and connected cases)
