Sakshi Arha v. Rajasthan High Court

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Reservation – Validity of OBC-NCL/MBC-NCL Certificates – Cut-off Date for Eligibility.

Held

In the absence of a specified cut-off date in recruitment advertisements, the last date for application submission is the default date for assessing eligibility, including the validity of reserved category certificates. OBC-NCL and MBC-NCL certificates are valid for one year, extendable to three years with an affidavit, as per Rajasthan State circulars. Certificates issued beyond this period are invalid for claiming reservation benefits. Subsequent notice clarifying cut-off date, aligning with existing rules and judicial precedents, is not arbitrary. Appellants’ certificates (issued 2012-2018) were invalid, and no relaxation permissible absent discretionary clause in rules. Appeals dismissed, upholding Rajasthan High Court’s exclusion of appellants from interviews for Civil Judge posts.

Ashok Kumar Sonkar v. Union of India, (2007) 4 SCC 54; Bhupinderpal Singh v. State of Punjab, (2000) 5 SCC 262; Rekha Chaturvedi v. University of Rajasthan, 1993 Supp (3) SCC 168 followed. Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board, (2016) 4 SCC 754 distinguished.

Case Details

  • Citation: 2025 (4) KLR (SC) 44 : 2025 INSC 463
  • Court: Supreme Court of India
  • Bench: Abhay S. Oka, Ahsanuddin Amanullah, Augustine George Masih, JJ.
  • Date of Judgment: April 8, 2025
  • Civil Appeal Nos.: 3957, 3958-3961, 3962, 3963, 3909 of 2023
  • Appellant: Sakshi Arha & Ors.
  • Respondent: The Rajasthan High Court & Ors.

Facts

  • The appeals arose from a split verdict by a Division Bench of the Supreme Court on May 18, 2023, concerning the appointment of Civil Judges under the Rajasthan Judicial Service Rules, 2010 (“2010 Rules”).
  • The Rajasthan High Court issued an advertisement on July 22, 2021, for the Civil Judge Examination 2021, with the last date for applications being August 31, 2021. The advertisement was silent on the cutoff date for reserved category certificates (OBC-NCL, MBC-NCL, EWS).
  • A Subsequent Notice dated August 4, 2022, required reserved category certificates to be issued on or before August 31, 2021, or between August 31, 2018, and August 30, 2020, with an affidavit for validity.
  • Appellants, belonging to reserved categories, cleared the preliminary and mains examinations but were excluded from interviews due to certificates issued before the specified cutoff (e.g., 2016-2018).
  • Appellants filed writ petitions in the Rajasthan High Court, which were dismissed based on precedents requiring valid certificates by the application deadline. The Supreme Court heard the appeals before a 3-Judge Bench due to the Division Bench’s split verdict.

Issues

  1. Whether the Subsequent Notice’s requirement for reserved category certificates to be issued on or before August 31, 2021, was arbitrary and violated the appellants’ rights.
  2. Whether the Rajasthan High Court’s reliance on precedents like Ashok Kumar Sonkar v. Union of India was appropriate.
  3. Whether the appellants’ reliance on Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board entitled them to relief.

Arguments

Appellants

  • The Subsequent Notice’s cutoff date was arbitrary, as the advertisement and 2010 Rules did not specify a deadline for certificate issuance.
  • Certificates issued earlier (e.g., 2016) were valid, as the advertisement only required a certificate in the prescribed format.
  • The Rajasthan High Court’s reliance on Ashok Kumar Sonkar was misplaced, as it dealt with income-based exclusions, not certificate validity.
  • Ram Kumar Gijroya supported their claim, as it allowed flexibility for certificate submission when no deadline was specified.
  • Cited Dolly Chhanda and Dheerender Singh Paliwal for instances of relaxations in document submission.

Respondents

  • The Subsequent Notice was consistent with State circulars (dated September 9, 2015, and August 8, 2019), stating that OBC-NCL/MBC-NCL certificates are valid for one year, extendable to three years with an affidavit.
  • The advertisement required a “legally valid certificate,” and the cutoff date of August 31, 2021, aligned with Ashok Kumar Sonkar, which deems the application deadline as the cutoff in the absence of a specified date.
  • Ram Kumar Gijroya was distinguishable, as appellants lacked valid certificates, and the case was referred to a larger bench without granting substantive relief.
  • Relaxation would prejudice other candidates who adhered to the cutoff, as per Rakesh Kumar Sharma.

Judgment

  • Held: The appeals were dismissed, upholding the Rajasthan High Court’s decision.
  • Reasoning:
    • The advertisement required certificates issued by competent authorities “as per rules,” which included State circulars limiting OBC-NCL/MBC-NCL certificate validity to one year, extendable to three years with an affidavit.
    • Supreme Court precedents (Bhupinderpal Singh, Rekha Chaturvedi, Ashok Kumar Sonkar) establish that eligibility, including certificate validity, is assessed as of the last date for application submission (August 31, 2021) when no cutoff is specified.
    • The Subsequent Notice was not arbitrary, as it aligned with the 2010 Rules, State circulars, and judicial precedents. It ensured fairness by applying a uniform cutoff.
    • Appellants’ certificates (issued between 2012-2018) were invalid, as they exceeded the three-year validity period and lacked accompanying affidavits.
    • Ram Kumar Gijroya was inapplicable, as it addressed delays in certificate issuance by authorities, not invalid certificates. The appellants had no pending applications for certificates.
    • The principle of ignorantia juris non excusat applied, as appellants were expected to know the legal requirements for certificate validity.
    • No relaxation was permissible, as the advertisement and rules lacked discretionary provisions, and granting relief would undermine fairness to other candidates.

Ratio Decidendi

  • In the absence of a specified cutoff date in recruitment advertisements, the last date for application submission is the default date for assessing eligibility, including the validity of reserved category certificates.
  • OBC-NCL/MBC-NCL certificates are valid for one year, extendable to three years with an affidavit, as per State guidelines. Certificates beyond this period are invalid for claiming reservation benefits.
  • Subsequent clarifications (e.g., notices) aligning with existing rules and precedents are not arbitrary if they enforce eligibility criteria consistently.

Obiter Dicta

  • The dynamic nature of OBC-NCL/MBC-NCL status, unlike SC/ST status, requires periodic verification due to changes in social or economic conditions, as established in Indra Sawhney.
  • Reservation benefits must exclude the creamy layer to ensure affirmative action reaches the genuinely disadvantaged.

Precedents Relied Upon

  • Ashok Kumar Sonkar v. Union of India (2007) 4 SCC 54
  • Bhupinderpal Singh v. State of Punjab (2000) 5 SCC 262
  • Rekha Chaturvedi v. University of Rajasthan 1993 Supp (3) SCC 168
  • Indra Sawhney v. Union of India 1992 Supp (3) SCC 217
  • Rakesh Kumar Sharma v. State (NCT of Delhi) (2013) 11 SCC 58

Conclusion

The Supreme Court dismissed the appeals, affirming that the Rajasthan High Court’s exclusion of appellants from interviews was lawful due to their invalid certificates. The decision reinforces the importance of adhering to eligibility criteria and certificate validity as per applicable rules and judicial precedents.

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