The Supreme Court of India has settled a long-running dispute over cadre allocation in the Indian Forest Service (IFS), holding that candidates from reserved categories who take relaxation at any stage of the examination cannot later claim a General Insider cadre, even if they score higher in the final merit list.
The ruling came in appeals filed by the Union of India and a general category candidate against a 2019 judgment of the Karnataka High Court, which had earlier favoured a Scheduled Caste officer.
Read also:- Himachal Pradesh High Court Grants Bail to Man Booked for Online Posts, Says Peaceful Criticism
Background of the Case
The case arose from the IFS Examination, 2013, conducted under the Civil Services framework.
G. Kiran, a Scheduled Caste (SC) candidate, and Antony S. Mariyappa, a General category candidate, both appeared in the examination.
At the Preliminary Examination stage, the general cut-off was 267 marks, while the relaxed cut-off for SC candidates was 233. Kiran scored 247.18 marks-below the general cut-off but above the SC cut-off-allowing him to progress to the Main Examination. Mariyappa cleared the preliminary stage under general standards.
In the final merit list, Kiran ranked 19, well ahead of Mariyappa at rank 37. Trouble began during cadre allocation. Karnataka had only one General Insider vacancy. The government allotted that post to Mariyappa, while Kiran was assigned the Tamil Nadu cadre.
Challenging this, Kiran approached the Central Administrative Tribunal, which ruled in his favour. The Karnataka High Court later upheld that decision, reasoning that the preliminary test was only a screening exercise.
The Supreme Court closely examined the IFS Examination Rules, 2013, and the Cadre Allocation Policy. The central question was whether a candidate who used relaxed standards in the preliminary stage could still be treated as selected on “general standards” for cadre allocation.
The bench emphasised that the examination is a two-tier process, and the preliminary stage, even if only for screening, remains an integral part of selection.
Read also:- Bombay High Court Quashes MPCB Circular, Restores Green Gene's Right to Collect Hazardous
Court’s Observations
Rejecting the High Court’s reasoning, the bench observed that relaxation taken at any stage has consequences later.
“The preliminary examination may be a screening test, but it is still a stage of the examination,” the court noted, adding that relaxation there cannot be ignored while allocating cadres.
The judges pointed to Rule 14 of the IFS Examination Rules, which clearly bars adjustment against unreserved vacancies if a candidate has taken relaxation in eligibility or selection criteria “at any stage of the examination.”
The court also relied on earlier judgments, reiterating that merit achieved after availing relaxation cannot erase the initial advantage taken.
Read also:- Gujarat High Court Seeks Policy Records to Verify Supreme Court Compliance on Prisoner Remission
Final Decision
Allowing the appeals, the Supreme Court set aside the Karnataka High Court’s 2019 judgment and the Tribunal’s order.
The bench held that G. Kiran, having qualified the preliminary examination using relaxed standards, could not be treated as a General category candidate for cadre allocation. As a result, the allocation of the Karnataka General Insider post to Antony S. Mariyappa was upheld.
Read also:- Supreme Court Restores Career of MP Judge, Sets Aside Removal Over Bail Orders After 27 Years
The notification issued by the Ministry of Environment, Forest and Climate Change in March 2015 was declared valid, and the appeals were disposed of with no order on costs.
Case Title: Union of India v. G. Kiran & Ors.
Case No.: Civil Appeal arising out of SLP (C) No. 4743 of 2020
Case Type: Service Law – Cadre Allocation
Decision Date: 6 January 2026
