A) ABSTRACT / HEADNOTE

The Supreme Court in Mohit Kumar v. State of Uttar Pradesh and Ors. dealt with the legality of the Uttar Pradesh Police Recruitment and Promotion Board’s insistence on candidates submitting Other Backward Class (OBC) certificates strictly in the prescribed State format for availing reservation benefits in recruitment to posts of Sub-Inspector, Platoon Commander, and Fire Officer. The controversy arose when candidates, including Mohit Kumar and Kiran Prajapati, submitted OBC certificates issued in the Central Government format instead of the format mandated by the recruitment notification. Despite belonging to recognized OBC communities and possessing valid certificates, their candidature under the reserved category was rejected, and they were treated as general candidates.

The Court held that although no statutory mandate directly required a certificate in the exact format prescribed, the recruitment notification’s terms were binding and mandatory. Once a recruitment process is initiated, equal treatment of all aspirants demands strict adherence to prescribed norms. Non-compliance with the specified format, even if the candidate substantively belonged to an OBC category, justified treating them as unreserved candidates. The Court further observed that recruitment authorities are the best judges of their requirements and that courts should not interfere unless there is arbitrariness or violation of constitutional guarantees under Articles 14 or 16.

This decision harmonized previous conflicting High Court rulings and underscored the principle that recruitment rules cannot be diluted by judicial sympathy. The Court distinguished precedents like Dolly Chhanda v. Chairman, JEE, Ram Kumar Gijroya v. DSSSB, and Karn Singh Yadav v. GNCTD, clarifying that procedural requirements tied to reservation eligibility cannot be relaxed if explicitly set out in recruitment notifications. The appeals were accordingly dismissed in respect of Mohit Kumar but allowed against Kiran Prajapati, thereby reinforcing uniform application of rules.

Keywords: OBC certificate, prescribed format, recruitment notification, reservation, Uttar Pradesh Police Recruitment and Promotion Board, equal treatment, public employment, selection process, Ahir community, unreserved category.

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGEMENT

The present appeals arose from divergent rulings of the Allahabad High Court regarding the acceptance of OBC certificates in recruitment to public employment under the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB). The case centered around Clause 5.4(4) of the recruitment notification dated 24 February 2021, which mandated submission of caste certificates in Format-I, prescribed by the State Government. It explicitly warned that failure to comply would result in the candidate being treated as belonging to the unreserved category.

Mohit Kumar, who belonged to the Ahir community recognized as OBC in Uttar Pradesh, submitted an OBC certificate issued in the Central Government format. Despite scoring higher than the OBC cut-off but below the general cut-off, his candidature under the OBC category was rejected. His representation was dismissed, and subsequently, the Allahabad High Court upheld the rejection. On the other hand, in a parallel matter, candidate Kiran Prajapati, who also submitted a Central format certificate, succeeded before a Single Judge and later before the Division Bench of the High Court, which directed UPPRPB to accept her OBC certificate. This conflicting judicial approach necessitated authoritative adjudication by the Supreme Court.

The case drew attention to fundamental questions regarding the balance between procedural technicalities and substantive justice in the implementation of reservation policy. While reservation under Article 16(4) of the Constitution aims to level the playing field for socially and educationally backward classes, the question was whether insistence on a specific format for certificates amounted to an excessive technicality that defeats the objective of reservation. Conversely, the State argued that adherence to format ensured uniformity, verification of non-creamy layer status, and avoidance of administrative arbitrariness.

The Court’s ruling addressed the principle of equality of opportunity in public employment under Article 14 and 16, the binding nature of recruitment notifications, and the jurisprudence of strict compliance with eligibility norms. It also clarified the role of courts in scrutinizing recruitment processes vis-à-vis administrative discretion and the scope of judicial intervention.

D) FACTS OF THE CASE

In February 2021, UPPRPB issued a notification for recruitment to the posts of Sub-Inspector, Platoon Commander, and Fire Officer for the year 2020–21. Clause 5.4(4) mandated that OBC candidates must submit caste certificates in Format-I prescribed by the State. Certificates in the Central Government format were expressly inadmissible, and such candidates were to be treated as general category aspirants.

Mohit Kumar applied for the post of Sub-Inspector in April 2021, participated in the examination, and scored 313.84 marks. The cut-off for OBC candidates was 305.542, while for general candidates, it was 316.11. Since Mohit had submitted a Central Government format OBC certificate, his claim to OBC status was rejected, and he was treated as a general category candidate, thereby falling short of the general cut-off. His representation to UPPRPB was rejected on 15 September 2022. A writ petition before the Allahabad High Court challenging this rejection was dismissed on 22 March 2023.

In the connected appeal, Kiran Prajapati, who also applied under the OBC category with a Central format certificate, secured 287 marks. She cleared the OBC cut-off of 285.92 but was excluded from the select list on the ground of non-submission of a certificate in Format-I. Unlike Mohit, her writ petition before a Single Judge succeeded, and the Division Bench upheld this decision, directing UPPRPB to accept her certificate. The State’s appeal to the Supreme Court arose from this ruling.

Thus, the appeals before the Supreme Court revolved around the single issue of whether OBC candidates who submitted caste certificates in the Central format, instead of the State-prescribed format, were entitled to reservation benefits in the recruitment process.

E) LEGAL ISSUES RAISED

i. Whether UPPRPB was legally bound to accept OBC certificates submitted in the Central Government format instead of the prescribed State format under Clause 5.4(4) of the recruitment notification?
ii. Whether rejection of such certificates violated Articles 14 and 16 of the Constitution by defeating the object of reservation?
iii. Whether procedural technicalities, such as the format of caste certificates, could override substantive entitlement to reservation?
iv. Whether courts can direct recruitment authorities to relax the requirements explicitly set out in recruitment notifications?

F) PETITIONER / APPELLANT’S ARGUMENTS

i. The counsel for Mohit contended that OBC certificates are issued by the same authority—the Tehsildar—for both Central and State purposes. Thus, rejection of a valid OBC certificate merely because of format amounted to excessive technicality and unjust denial of reservation benefits.

ii. It was argued that Mohit secured marks higher than the OBC cut-off and only marginally below the general cut-off. His substantive entitlement to OBC reservation was disregarded in favor of a technical procedural requirement.

iii. Reliance was placed on Dolly Chhanda v. Chairman, JEE (2005) 9 SCC 779, where the Court held that minor infractions should not result in rejection of candidature if substantive eligibility is established.

iv. In Dheerender Singh Paliwal v. UPSC (2017) 11 SCC 276, the Court held that candidates could be given an opportunity to rectify deficiencies in certificates.

v. Ram Kumar Gijroya v. DSSSB (2016) 4 SCC 754 and Karn Singh Yadav v. GNCTD (2024) 2 SCC 588 were cited to stress that the purpose of reservation is to provide equal opportunity, and excessive technicality undermines this constitutional objective.

vi. The Ahir community’s recognition as OBC in Uttar Pradesh was undisputed, and hence denial of reservation benefits to Mohit was inequitable.

G) RESPONDENT’S ARGUMENTS

i. Counsel for the State emphasized that Clause 5.4(4) of the recruitment notification clearly mandated submission of OBC certificates in Format-I. Candidates failing to comply were deemed general candidates, a condition that was explicitly notified.

ii. The requirement ensured compliance with State-specific definitions of the non-creamy layer, which differ from those applied by the Central Government. The Central format did not verify annual income and wealth criteria under the Wealth Tax Act, 1957 and Government Order dated 17 December 2014.

iii. The principle laid down in Bedanga Talukdar v. Saifudaullah Khan (2011) 12 SCC 85 was invoked, holding that relaxation of recruitment rules is impermissible unless specifically provided.

iv. Reliance was also placed on State of Tamil Nadu v. G. Hemalathaa (2020) 19 SCC 430, where strict adherence to recruitment rules was upheld.

v. The Full Bench ruling in Gaurav Sharma v. State of U.P. 2013 SCC OnLine All 1286 affirmed that the State’s criteria for creamy layer verification are distinct and binding.

vi. The State argued that allowing Central format certificates would impose administrative burdens, requiring verification of each candidate’s eligibility under State norms, contrary to the efficiency and uniformity of the recruitment process.

H) JUDGEMENT

The Supreme Court held that although no statutory law mandated submission of certificates in a particular format, the recruitment notification had binding force. Once candidates participated in the process without raising objections, they were bound by its terms. The insistence on a specific format was not a mere formality but essential to ensure uniform verification of eligibility and prevent administrative arbitrariness.

The Court emphasized that terms of recruitment advertisements are not open to judicial challenge except where they violate Articles 14 or 16. Candidates had the opportunity to seek clarification or obtain a State format certificate, but having failed to do so, they could not claim relaxation.

Accordingly, Mohit Kumar’s appeal was dismissed, affirming the High Court’s decision against him. Conversely, the appeal against Kiran Prajapati was allowed, setting aside the High Court’s direction to accept her certificate, thereby ensuring consistency in applying the rule.

a. RATIO DECIDENDI

The ratio decidendi of the case is that submission of caste certificates in the format prescribed by the recruitment notification is mandatory and non-compliance justifies treating candidates as unreserved. The Court reiterated that recruitment authorities are the best judges of their requirements, and courts must defer to their understanding unless constitutional guarantees are breached.

This principle derives support from Registrar General, Calcutta High Court v. Shrinivas Prasad Shah (2013) 12 SCC 364, where the Court held that absence of a certificate from the competent authority disqualified a candidate from reservation benefits. Similarly, Bedanga Talukdar and Hemalathaa reinforced that recruitment conditions cannot be relaxed judicially unless expressly permitted.

b. OBITER DICTA

In its observations, the Court noted that while the objective of reservation is to remove inequalities, candidates themselves bear the responsibility to comply with recruitment requirements. Even if terms of the notification appear ambiguous, aspirants must seek clarification rather than assume compliance. The Court distinguished earlier decisions like Dolly Chhanda and Ram Kumar Gijroya, holding that those applied to situations where substantive eligibility was established but minor curable defects existed. Here, the requirement was categorical and non-negotiable.

The Court also observed that although some High Court rulings in similar matters had granted relief, dismissal of special leave petitions at the admission stage did not create binding precedent.

c. GUIDELINES

The Court laid down the following guiding principles:

i. Recruitment notifications are binding: Terms must be complied with strictly, and courts will not dilute them except for constitutional violations.
ii. Equal treatment of aspirants: All candidates must adhere to the same requirements; differential relaxation creates arbitrariness.
iii. Responsibility of candidates: Aspirants must seek clarification or obtain fresh certificates in the prescribed format, rather than rely on assumptions.
iv. Administrative discretion: Recruiting authorities are best positioned to determine procedural requirements for verifying eligibility.
v. Judicial restraint: Courts should refrain from interfering with recruitment rules unless they are arbitrary, discriminatory, or violative of Articles 14 and 16.

I) CONCLUSION & COMMENTS

The decision in Mohit Kumar v. State of Uttar Pradesh reinforces the doctrine of strict compliance with recruitment notifications and underscores that procedural uniformity is essential for fairness in public employment. While the petitioners highlighted the inequity of losing reservation benefits due to format discrepancies, the Court rightly prioritized legal certainty and equal treatment over individual hardship.

The ruling harmonizes conflicting High Court precedents and clarifies that recruitment authorities have discretion to prescribe certificate formats, which cannot be challenged unless discriminatory. It also reflects judicial restraint in service law, emphasizing that courts cannot rewrite recruitment rules under the guise of equity.

From a policy perspective, the judgment strengthens the integrity of the reservation system by ensuring uniform verification of non-creamy layer status. At the same time, it highlights the need for administrative authorities to ensure greater awareness and facilitation for candidates, especially those from marginalized backgrounds, to avoid procedural disqualification.

Ultimately, the judgment balances constitutional guarantees of equality with the practical necessities of recruitment administration, setting a precedent for future cases involving procedural compliance in reservation-linked employment processes.

J) REFERENCES

a. Important Cases Referred

i. Registrar General, Calcutta High Court v. Shrinivas Prasad Shah, (2013) 12 SCC 364.
ii. Bedanga Talukdar v. Saifudaullah Khan, (2011) 12 SCC 85.
iii. State of Tamil Nadu v. G. Hemalathaa, (2020) 19 SCC 430.
iv. Dolly Chhanda v. Chairman, JEE & Ors., (2005) 9 SCC 779.
v. Dheerender Singh Paliwal v. UPSC, (2017) 11 SCC 276.
vi. Ram Kumar Gijroya v. DSSSB & Anr., (2016) 4 SCC 754.
vii. Karn Singh Yadav v. GNCT of Delhi & Ors., (2024) 2 SCC 588.
viii. Meeta Sahai v. State of Bihar, (2019) 20 SCC 17.
ix. Gaurav Sharma v. State of U.P., 2013 SCC OnLine All 1286.

b. Important Statutes Referred

i. Constitution of India, Articles 14 and 16.
ii. Uttar Pradesh Public Services (Reservation for SC, ST and OBC) Act, 1994.
iii. Uttar Pradesh Sub-Inspector and Inspector (Civic Police) Service (Amended) Rules, 2015.
iv. Wealth Tax Act, 1957.
v. Government Order dated 17 December 2014 under the 1994 Act.