15 May 2025 Civil Appeals >> Civil & Consumer Law   |   Education >> Miscellaneous  

The Supreme Court of India has ruled on a common question of law concerning the mandatory nature of prescribed formats for Other Backward Class (OBC) certificates in government recruitment processes. The decision came while adjudicating two civil appeals arising from differing outcomes in the Allahabad High Court, both pertaining to the same recruitment for Sub-Inspector and other allied posts in the Uttar Pradesh Police.

The Court dismissed the appeal filed by Mohit Kumar, whose candidature was rejected for not submitting his OBC certificate in the format prescribed by the State Government. Conversely, the Court allowed the appeal filed by the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) in the case of Kiran Prajapati, whose earlier successful challenge in the High Court for the same issue has now been overturned.

The Cases at Hand:

Mohit Kumar's Case: Mohit Kumar applied for Sub-Inspector and Platoon Commander posts in response to a February 2021 recruitment notification by the UPPRPB. He scored 313.84 marks, which was above the OBC cut-off (305.542) but below the General category cut-off (316.11). His candidature was rejected because he submitted an OBC certificate in the format prescribed for Central Government services, not the one mandated by the State Government's recruitment notification. His representation and subsequent writ petition challenging the rejection were dismissed by the Allahabad High Court.

Kiran Prajapati's Case: Kiran Prajapati also applied for the Sub-Inspector post under the same notification, in the OBC category. She scored 287 marks, exceeding the OBC cut-off (285.92) but falling short of the General category cut-off (296.597). Her application was also rejected for submitting a Central Government OBC certificate. However, a Single Judge of the Allahabad High Court allowed her writ petition, directing UPPRPB to accept her certificate. This decision was upheld by a Division Bench of the High Court.

Arguments Presented:

For the State of Uttar Pradesh and UPPRPB (Appellants in Mohit's case, Respondents in Kiran's case): Ms. Ruchira Goel, counsel for the State and UPPRPB, argued that the recruitment was governed by the Uttar Pradesh Sub-Inspector and Inspector (Civic Police) Service (Amended) Rules, 2015, and the Uttar Pradesh Public Services (Reservation for Schedule Castes, Schedule Tribes and Other Backward Classes) Act, 1994. A key point was Clause 5.4(4) of the recruitment advertisement, which explicitly stated that candidates failing to submit the OBC certificate in the prescribed Format-I for State Government services, or submitting a Central Government format certificate, would be treated as unreserved candidates.

She emphasized that Format-I specifically requires details regarding parental gross annual income and wealth, crucial for ascertaining the creamy layer exclusion as per State Government orders (G.O. dated December 17, 2014). This information, she argued, is not present in Central Government OBC certificates. Insisting on the State-prescribed format prevents an undue burden on the State machinery to verify individual creamy layer status for those submitting Central Government certificates. She cited the Full Bench decision in Gaurav Sharma v. State of U.P. and Bedanga Talukdar v. Saifudaullah Khan to support the strict adherence to recruitment rules.

For Mohit Kumar and Kiran Prajapati (Respondents): Mr. Rahul Kaushik, senior counsel for Mohit, contended that both Central and State OBC certificates are issued by the Tehsildar and that rejecting a candidate based on a specific format was overly technical, especially when the candidate clearly belonged to the recognized OBC community and secured marks above the OBC cut-off. He highlighted Mohit's disadvantaged background and cited Supreme Court decisions like Dolly Chhanda v. Chairman, Jee & Ors. (every infraction of rule may not lead to rejection), Dheerender Singh Paliwal v. Union Public Service Commission (authorities could seek clarification), and Ram Kumar Gijroya v. Delhi Subordinate Services Selections Board and Karn Singh Yadav v. Government of NCT of Delhi & Ors. (reservations aim to remove inequalities and technicalities should not frustrate this object). Mr. Kumar Gaurav, counsel for Kiran, adopted these submissions.

Supreme Court's Verdict:

The core issue before the Supreme Court was whether UPPRPB was obligated to accept OBC certificates not submitted in the prescribed format.

The Court relied on its earlier decision in Registrar General, Calcutta High Court v. Shrinivas Prasad Shah and Ors., which established that irrespective of a candidate's community status, the claim for reservation benefits must be certified by the competent authority following due process and in the prescribed manner. The Court affirmed that while Shrinivas Prasad Shah involved a statutory mandate, the requirement in the present case, though derived from a recruitment notification, was no less mandatory and had to be scrupulously followed.

The bench stressed that "once a process of recruitment is set in motion, all aspirants are entitled in law to equal treatment. There cannot be different yardsticks for different sets of aspirants." It underscored that non-compliance with the terms of the advertisement would justify the rejection of an aspirant's claimed status.

The Court found Clause 5.4(4) of the recruitment notification to be "far from ambiguous" and "absolutely clear" regarding the consequence of non-adherence. It stated that candidates had no reason to doubt the required format and could have sought clarification or obtained the correct certificate.

The Court also accepted the UPPRPB's rationale for insisting on the specific format, primarily to ensure proper ascertainment of the creamy layer as per State Government rules, which differ from Central Government norms concerning income and wealth criteria.

While acknowledging that previous High Court decisions (uninterfered with by the Supreme Court at admission stage) might have granted relief to similarly placed candidates, the Court clarified that these did not set binding precedents.

Conclusion:

Based on the reasoning, the Supreme Court concluded that Mohit Kumar and Kiran Prajapati were not entitled to any relief. Consequently, Mohit Kumar's appeal was dismissed, affirming the High Court's decision to reject his writ petition. Conversely, the UPPRPB's appeal against Kiran Prajapati was allowed, setting aside the High Court's judgment that had favored her. This ruling reinforces the principle that candidates must strictly adhere to the specific requirements, including document formats, outlined in recruitment notifications, particularly when such requirements are clear and serve a specific purpose like ensuring proper implementation of reservation policies.