The Supreme Court of India, in Mohit Kumar v State of Uttar Pradesh & Ors [Civil Appeal No. 5233 of 2024] recently held that candidates cannot claim reservation if the caste certificate is not submitted in the prescribed format. The appeals arose from orders passed by the Allahabad High Court on separate Writ Petitions related to the same recruitment process but outcomes of the said Writ Petitions were different. The Uttar Pradesh Police Recruitment and Promotion Board (“UPPRPB”) had issued notifications for direct recruitment to several posts for which the candidates had applied. The Appellants therein had applied for the posts under the Other Backward Classes (“OBC”) category. The issue arose when it was found that the certificates were not submitted in the prescribed format. Consequently, some of the candidates including Mr. Manoj Kumar and Ms. Kiran Prajapati, were not selected. Aggrieved by the result and after receiving no response to their representations from the departments, the applicants separately filed writ petitions in the Allahabad High Court.
In Manoj Kumar’s case, the High Court directed the concerned department to issue a reasoned order. Following the court’s directions, the UPPRPB issued a speaking order stating that the candidate had not submitted the OBC certificate in the required format and was therefore considered under the general category, which led to his non-selection. In Kiran Prajapati’s case, the High Court directed the department to consider the candidate’s application, following which the UPPRPB preferred an appeal before the division bench, which upheld the decision of the single judge.
While deciding both connected matters, the Supreme Court held that merely claiming a particular status to avail the benefit of reservation does not conclusively prove or determine the matter. Such status must be certified by the competent authority upon following due process and identification. The Court further held that once the recruitment process begins, all aspirants are entitled to equal treatment. The Court emphasized that there cannot be different yardsticks for different aspirants, and non-compliance with the advertisements or notifications is bound to attract adverse consequences.
The Court clarified that it is a settled point of law that the terms of an advertisement are generally not open to challenge unless they violate Article 14 or Article 16 of the Constitution. Applicants must make an effort to seek clarity if they find any term ambiguous or in need of inquiry. The Court held that it is not only a responsibility but a duty of aspirants to read, note, and understand the requirements of the terms. Without such efforts, candidates cannot challenge the selection on the ground that a disputed term could have different interpretations. The Court also noted that the provisions in question were far from ambiguous and reiterated the principle that the recruitment authority is the best judge of its requirements. The Supreme Court dismissed the lead matter filed by the candidate against his rejection on ground of faulty caste certificate and allowed the connected matter by the State