Case Note & Summary
The Supreme Court dismissed two appeals arising from a common recruitment process for Sub-Inspector posts conducted by the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB). The core issue was whether candidates who submitted OBC certificates in the format prescribed for Central Government employment, instead of the State Government format mandated by the recruitment notification, could claim the benefit of OBC reservation. The notification explicitly stated in clause 5.4(4) that candidates failing to submit the OBC certificate in the prescribed format or submitting a Central Government certificate would be treated as unreserved category candidates. Mohit Kumar and Kiran Prajapati, both OBC candidates, submitted Central Government format certificates. Mohit scored 313.84 marks, above the OBC cut-off of 305.542, but was treated as general category where the cut-off was 316.11, leading to his non-selection. Kiran scored 287 marks, above the OBC cut-off of 285.92, but was also rejected. The High Court dismissed Mohit's writ petition but allowed Kiran's, leading to cross-appeals. The Supreme Court held that the requirement in the notification was mandatory and non-compliance justified rejection. The court noted that the State Government's format includes specific income and wealth criteria for creamy layer determination, which are not present in the Central Government certificate. The court rejected arguments that the candidates' hard work should be considered or that minor infractions should be overlooked, emphasizing that relaxation of eligibility conditions is not permissible unless rules expressly provide. The court also noted that vacancies were carried forward to the next selection. Consequently, the appeal by Mohit was dismissed, and the appeal by the State against Kiran's selection was allowed, setting aside the High Court's order.
Headnote
A) Service Law - Recruitment - OBC Certificate Format - Strict Compliance - Uttar Pradesh Sub-inspector and Inspector (Civic Police) Service (Amended) Rules, 2015 - The court considered whether candidates who submitted OBC certificates in Central Government format instead of State Government format as required by the recruitment notification could claim OBC reservation. Held that the requirement in clause 5.4(4) of the advertisement was mandatory and non-compliance justified rejection of candidature (Paras 1-12). B) Service Law - Reservation - Creamy Layer - Financial Criteria - Uttar Pradesh Public Services (Reservation for Schedule Castes, Schedule Tribes and Other Backward Classes) Act, 1994 - The court examined the rationale behind requiring OBC certificates in the prescribed format to ascertain creamy layer status as per State Government norms. Held that the format prescribed by the State Government includes specific income and wealth criteria not found in Central Government certificates, making compliance essential (Paras 9-12). C) Service Law - Recruitment - Relaxation of Eligibility Conditions - Not Permitted - The court rejected the argument that minor infractions should be overlooked, citing Bedanga Talukdar v. Saifudaullah Khan. Held that relaxation of eligibility conditions is not permissible unless rules expressly provide for it (Paras 9-12).
Issue of Consideration
Whether UPPRPB was bound to accept OBC certificates submitted by candidates which were not in the format prescribed in the Recruitment Notification.
Final Decision
Civil Appeal No. 5233 of 2025 (Mohit Kumar) dismissed; Civil Appeal No. 5234 of 2025 (State of U.P.) allowed, setting aside the High Court order in Kiran Prajapati's case.
Law Points
- Strict compliance with recruitment notification requirements
- OBC certificate format
- distinction between Central and State Government OBC certificates
- no relaxation of eligibility criteria
