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Supreme Court: No Reservation Without Submitting Caste Certificate in Prescribed Format

17 May 2025 3:53 PM - By Vivek G.

Supreme Court: No Reservation Without Submitting Caste Certificate in Prescribed Format

The Supreme Court has emphasized that candidates seeking reservation under a specific category must submit their caste certificate in the format prescribed in the recruitment advertisement. This ruling was delivered by a bench comprising Justice Dipankar Datta and Justice Manmohan, who dismissed an appeal by a candidate applying for a position with the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB). The candidate had submitted an OBC certificate in a format meant for central government jobs instead of the state-prescribed format.

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The court highlighted that failure to submit the certificate in the specified format would result in the candidate being considered under the unreserved category. The judgment stressed that non-compliance with the advertisement’s terms would directly impact the candidate's eligibility.

The candidate, after being denied selection due to submitting an incorrect format certificate, initially approached the Allahabad High Court. The High Court rejected his plea, leading him to file an appeal with the Supreme Court. Upholding the High Court’s decision, the Supreme Court referred to the case of Registrar General, Calcutta High Court v. Shrinivas Prasad Shah (2013) 12 SCC 364, which mandates that certificates must be issued by a competent authority in the format prescribed by the advertisement.

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  • On Compliance:
    “Non-compliance with the terms of the advertisement/notification is bound to trigger adverse consequences of rejection of the aspirant's claimed status by the selecting body/appointing authority, should he choose not to adhere to the same.” – Supreme Court.
  • Recruitment Authority’s Role:
    The Court emphasized that the recruiting authority is the best judge of the process, and courts generally should not interfere once the recruitment process has begun.
  • Candidate’s Responsibility:
    Candidates are expected to read and understand the recruitment notification carefully. Any misunderstanding or wrong submission due to their negligence cannot be a valid ground for challenging the process later.
  • Misinterpretation Not Excusable:
    “If the aspirant does not make any such effort and takes a calculated chance of selection based on his own understanding of the disputed term in the advertisement and later, he emerges unsuccessful, ordinarily, it would not be open to him to challenge the selection on the ground that the disputed term is capable of being understood differently.” – Supreme Court.

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The Supreme Court clarified that candidates cannot argue that submission of a caste certificate in a specific format is a mere technicality. They are expected to obtain the correct certificate format from the concerned authority before applying.

Dismissing the appeal, the court reaffirmed that the UPPRPB was justified in rejecting the candidate’s application due to non-compliance with the prescribed format.

Case Title: MOHIT KUMAR VERSUS STATE OF UTTAR PRADESH AND ORS. (and connected case)

Appearance:

For Petitioner(s) :Mr. Rahul Kaushik, Sr. Adv. Mr. Kumar Gaurav, Adv. Mr. Tom Joseph, AOR Ms. Kristen Sleeth, Adv. Ms. Ruchira Goel, AOR Ms. Veera Mahuli, Adv. Mr. Sharanya Singh, Adv.

For Respondent(s) :Ms. Ruchira Goel, AOR Ms. Veera Mahuli, Adv. Mr. Sharanya Singh, Adv. Mr. Kumar Gaurav, Adv. Mr. Tom Joseph, AOR Ms. Arya Krishnan, Adv. Mr. Prashant Bhardwaj, Adv.