A) ABSTRACT / HEADNOTE

The judgment in Saurav Yadav & Ors. v. State of Uttar Pradesh & Ors. settles a long-standing conflict concerning the correct application of horizontal reservation vis-à-vis vertical reservation in public employment. The controversy arose from the recruitment of constables in the Uttar Pradesh Police pursuant to the 2013 selection process, where female candidates belonging to reserved categories, despite securing marks higher than the last selected candidate in the General Female Category, were denied placement in the open category. The State justified this exclusion by relying on judicial precedents of the Allahabad and Madhya Pradesh High Courts which had adopted an interpretation that prevented such migration.

The Supreme Court decisively rejected this interpretation, holding that the open/general category is not a reserved compartment, but one that is available to all candidates solely on the basis of merit. The Court reaffirmed that horizontal reservation is interlocking in nature and does not operate as a rigid quota excluding meritorious candidates merely because they belong to reserved social categories. The ruling harmonises constitutional principles under Articles 14 and 16 with established precedents such as Indra Sawhney, Anil Kumar Gupta, and Rajesh Kumar Daria.

The Court disapproved the so-called “second view” adopted by certain High Courts and approved the “first view” which prioritises merit in open category selection. Relief was moulded to protect existing appointees while extending appointment to eligible OBC female candidates. The decision strengthens the constitutional mandate of equality of opportunity and prevents artificial compartmentalisation that undermines merit.

Keywords: Horizontal Reservation, Vertical Reservation, Merit, Open Category, Equality in Public Employment

B) CASE DETAILS

C) INTRODUCTION AND BACKGROUND OF JUDGMENT

The case emerged from systemic inconsistencies in the application of reservation policies during large-scale public recruitment. The 2013 constable recruitment in Uttar Pradesh involved over forty-one thousand posts and a complex reservation framework combining vertical social reservations and horizontal special reservations for women. Judicial interventions in related recruitment processes, including disputes concerning disqualification for use of blades or whiteners, led to repeated reworking of merit lists and surplus appointments.

Against this backdrop, female candidates from OBC and SC categories, who secured marks exceeding the cut-off for General Female candidates, sought inclusion in the open category. Their exclusion was defended by the State on the basis of High Court judgments that interpreted horizontal reservation as barring migration to the open category once a candidate applied under a reserved category.

This interpretation created an anomalous situation where less meritorious general candidates were appointed over more meritorious reserved category candidates. The conflict between High Court views across different States necessitated authoritative clarification by the Supreme Court. The present judgment addresses this constitutional inconsistency and reasserts the primacy of merit within the framework of equality.

D) FACTS OF THE CASE

The applicants participated in the 2013 Uttar Pradesh Police Constable Recruitment. Applicant No. 1, belonging to the OBC-Female category, secured 276.5949 marks, while Applicant No. 2 from the SC-Female category secured 233.1908 marks. The cut-off for General Female candidates was 274.8928 marks. Despite scoring higher than the last selected General Female candidate, Applicant No. 1 was not considered for appointment.

Following earlier Supreme Court directions in Hanumant Dutt Shukla v. State of U.P., the selection list was reworked to accommodate candidates previously disqualified for technical reasons. Additional vacancies arose due to improper carry-forward of horizontal reservation vacancies, leading to further selection exercises in 2019. The State filled 188 General Female posts but restricted eligibility to women not belonging to SC, ST, or OBC categories.

The applicants challenged this exclusion, contending that it violated merit-based selection and equality. The State relied on prior Allahabad High Court rulings which held that horizontal reservation candidates must be adjusted only within their respective social categories. The Supreme Court was thus called upon to determine whether such exclusion was constitutionally permissible.

E) LEGAL ISSUES RAISED

i. Whether candidates belonging to reserved categories can be denied selection in the open/general category despite securing higher merit?

ii. Whether horizontal reservation operates as a rigid compartment restricting migration to the open category?

iii. Whether the interpretation adopted by the Allahabad and Madhya Pradesh High Courts violates Articles 14 and 16 of the Constitution?

F) PETITIONER / APPELLANT’S ARGUMENTS

The counsels for the petitioners submitted that horizontal reservation is interlocking and does not negate merit-based placement in the open category. Reliance was placed on Indra Sawhney, Anil Kumar Gupta, and Rajesh Kumar Daria to assert that candidates securing selection on merit must be placed in the open category irrespective of their social classification. The exclusion of OBC female candidates was argued to be arbitrary and discriminatory.

G) RESPONDENT’S ARGUMENTS

The counsels for the State contended that once candidates applied under a reserved category, they could not be shifted to the open category under horizontal reservation. Reliance was placed on Ashish Kumar Pandey and Ajay Kumar decisions of the Allahabad High Court. The State argued that allowing such migration would distort the reservation structure and exceed permissible limits.

H) RELATED LEGAL PROVISIONS

i. Article 14 of the Constitution of India
ii. Article 16(1) and 16(4) of the Constitution of India
iii. U.P. Act No. 4 of 1993

I) JUDGEMENT

The Supreme Court rejected the State’s position and disapproved the “second view” adopted by the Allahabad and Madhya Pradesh High Courts. It held that open category seats are not reserved seats and must be filled purely on merit. Any interpretation that results in selection of less meritorious candidates over more meritorious ones violates equality.

a) RATIO DECIDENDI

The Court held that horizontal and vertical reservations are mechanisms of representation and not barriers to merit. Migration from reserved categories to the open category on merit is constitutionally permissible and essential to preserve equality. Denial of such migration leads to communal compartmentalisation and undermines Articles 14 and 16.

b) OBITER DICTA

The Court observed that treating open category posts as reserved for non-reserved candidates would distort constitutional intent and result in irrational outcomes, particularly where women candidates form a significant proportion of the merit list.

c) GUIDELINES

i. Open category selection must be strictly merit-based.
ii. Horizontal reservation must be applied through adjustment, not exclusion.
iii. Existing appointees should not be disturbed where equities demand protection.

J) CONCLUSION & COMMENTS

The judgment restores doctrinal clarity to reservation jurisprudence and prevents mechanical application of horizontal reservation that negates merit. By affirming that the open category remains open to all, the Court reinforces constitutional equality and uniformity across States. The ruling has significant implications for future recruitment processes and ensures that reservation policies serve inclusion without sacrificing merit.

K) REFERENCES

a) Important Cases Referred

Indra Sawhney v. Union of India, [1992] Supp (3) SCC 217
Anil Kumar Gupta v. State of U.P., [1995] 2 Supp SCR 396
Rajesh Kumar Daria v. RPSC, [2007] 8 SCR 972
Hanumant Dutt Shukla v. State of U.P., [2018] 14 SCR 328

b) Important Statutes Referred

Constitution of India
Uttar Pradesh Public Services (Reservation) Act, 1993