Supreme Court Upholds Rajasthan High Court’s Decision on Validity of OBC-NCL Certificates for Civil Judge Recruitment
The Supreme Court of India recently delivered a significant judgment in the case of Sakshi Arha vs. The Rajasthan High Court & Ors., addressing the validity of OBC-NCL (Other Backward Classes – Non-Creamy Layer) certificates for recruitment to the Civil Judge Cadre in Rajasthan. The judgment, pronounced on April 08, 2025, by a 3-Judge Bench comprising Justices Abhay S. Oka, Ahsanuddin Amanullah, and Augustine George Masih, upheld the Rajasthan High Court’s decision, dismissing the appeals filed by the candidates.
Background of the Case
The case originated from an advertisement issued by the Rajasthan High Court on July 22, 2021, inviting applications for the post of Civil Judge under the Rajasthan Judicial Service Rules, 2010. The advertisement was silent about the last date for the issuance of reserved category certificates. However, a subsequent notice dated August 04, 2022, clarified that the certificates should have been issued by August 31, 2021, the last date for submitting applications.
The appellants, belonging to OBC-NCL, MBC-NCL (Most Backward Classes – Non-Creamy Layer), and EWS (Economically Weaker Section) categories, had cleared the preliminary and mains examinations but were excluded from the interview list because their certificates were issued after the cut-off date specified in the subsequent notice.
Arguments of the Petitioners
The appellants argued that:
- The advertisement did not specify any cut-off date for the issuance of certificates, making the subsequent notice arbitrary and unjust.
- They relied on the Supreme Court’s decision in Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board and Another, which held that the absence of a specified date in the advertisement means no such requirement can be imposed later.
- They contended that their certificates, issued in earlier years, were valid and should be accepted, as the advertisement only required a certificate in the prescribed format.
- They cited Dolly Chhanda v. Chairman, JEE and Others and Dheerender Singh Paliwal v. Union Public Service Commission, where relaxations were granted for document submissions.
Arguments of the Respondents
The Rajasthan High Court, represented by its Senior Advocate, countered that:
- The benefit of reservation is contingent on having a valid Non-Creamy Layer (NCL) certificate, which, as per Rajasthan government circulars dated September 09, 2015, and August 08, 2019, is valid only for one year and extendable up to three years with an affidavit.
- The advertisement required candidates to produce a legally valid certificate, and the subsequent notice was in line with the existing rules and circulars.
- They relied on Ashok Kumar Sonkar v. Union of India and Others, which held that in the absence of a specified cut-off date, the last date for application submission is deemed the cut-off date.
- They distinguished Ram Kumar Gijroya (supra), stating that the appellants did not possess valid certificates as per the rules.
Key Observations of the Supreme Court
The Supreme Court made several critical observations:
- Dynamic Nature of OBC-NCL Status: The Court noted that unlike SC/ST status, which is determined by birth, OBC-NCL status is subject to change based on social and economic conditions. This dynamic nature necessitates periodic validation of certificates.
- Validity of Certificates: The Court referred to Rajasthan government circulars, which clearly state that NCL certificates are valid for one year and can be extended up to three years with an affidavit. None of the appellants met this requirement.
- Cut-off Date for Eligibility: The Court reiterated the principle from Bhupinderpal Singh v. State of Punjab and Rekha Chaturvedi v. University of Rajasthan that eligibility must be determined as of the last date for application submission unless specified otherwise.
- Subsequent Notice Not Arbitrary: The Court held that the subsequent notice specifying the cut-off date was based on valid legal principles and government circulars, and thus, not arbitrary.
Important Verbatim Arguments from the Judgment
The Court quoted several key passages from its decisions:
“The eligibility criteria for candidates aspiring public employment shall be determined pertaining to the cut-off date as outlined in the applicable rules of their respective service. In case the rules are silent, the decisive date is, ideally, indicated in the advertisement for recruitment.” — Bhupinderpal Singh v. State of Punjab
“The date of selection is invariably uncertain. In the absence of knowledge of such date the candidates who apply for the posts would be unable to state whether they are qualified for the posts in question or not.” — Rekha Chaturvedi v. University of Rajasthan
Conclusion
The Supreme Court dismissed the appeals, upholding the Rajasthan High Court’s decision. The Court emphasized that the appellants failed to meet the eligibility criteria as per the advertisement and subsequent notice, and no relaxation could be granted in the absence of a discretionary clause. The judgment reinforces the importance of adhering to prescribed rules and cut-off dates in recruitment processes.
Petitioner Name: Sakshi Arha.Respondent Name: The Rajasthan High Court & Ors..Judgment By: Justice Abhay S. Oka, Justice Ahsanuddin Amanullah, Justice Augustine George Masih.Place Of Incident: Rajasthan.Judgment Date: 08-04-2025.Result: dismissed.
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