Allahabad High Court Orders UPPSC to Overhaul Preliminary Exam Results for Engineering Services

In a landmark decision that reinforces the principle of merit-based competition in public services, the Allahabad High Court has directed the Uttar Pradesh Public Service Commission ( UPPSC ) to revise its preliminary examination results for the 2024 Engineering and Technical services recruitment. Justice Ajit Kumar ruled that the Commission must adjust the merit list to allow meritorious reserved category candidates to compete within the unreserved (open) category at the preliminary screening stage.

The Spark of Discontent: A Rigid Screening Process

The legal battle originated from the recruitment process for 609 posts, including Assistant Engineers and District Horticulture Officers. The petitioners challenged the publication of results on May 26, 2025, which qualified 7,358 candidates. They argued that the Commission failed to adhere to the advertised 1:15 ratio, essentially keeping reserved category candidates confined to their specific quotas, even when their scores exceeded the cut-off for the unreserved category.

The UPPSC , represented by Senior Advocate Anoop Trivedi, defended its practice by arguing that current rules and previous government memoranda necessitated category-specific lists to ensure "adequate representation" and to maintain a "level playing field." The Commission further referenced ongoing legal uncertainty regarding migration at the preliminary stage in other High Courts .

The Crux: Is the Open Category Truly Open?

The Court’s analysis centered on the constitutional mandate of Article 16 and the definition of the "open category." Challenging the notion that the unreserved category is a reserve in itself, the Court held that a reserved category candidate who performs at par with or better than the last unreserved candidate must, by constitutional logic, be treated as an open-category candidate.

"Whoever performs better/equal to a candidate of unreserved category would automatically fall in unreserved category, it being open to all as has been held in Saurav Yadav ," Justice Ajit Kumar observed, dismissing the argument that category-wise publishing of results justifies the exclusion of meritorious individuals from the open stream.

Legal Precedents and Judicial Reasoning

The Court drew significant strength from the Supreme Court ’s ruling in Saurav Yadav v. State of U.P. and the Division Bench precedent in U.P. Power Corporation Ltd v. Nitin Kumar . Rejecting the plea that internal memoranda could circumvent the foundational principles of merit, Justice Kumar emphasized that the "open category" serves as a benchmark for excellence, regardless of social background.

The Court distinguished the present case from other High Court rulings currently under stay by the Supreme Court , noting that the principle of migration as a facet of meritocracy remains settled law under the doctrine of stare decisis regarding the Supreme Court 's directives in Saurav Yadav .

Key Observations

The judgment offers a scathing critique of systems that artificially cap merit:

• "The open category is not a ‘quota’, but rather available to all women and men alike."
• "Confining such a candidate to the reserved category only for the reason that list has been published category-wise, would definitely amount to discrimination."
• "Equality before law and equal protection of laws means ‘likes to be treated alike’ and hence whoever competes with the candidates of open category and falls within the cutoff of that category as may be prescribed, would constitute a class for limited purposes."

Practical Implications and Final Order

The Allahabad High Court has ordered the UPPSC to "re-draw the merit list of the preliminary examination result of suitable candidates to qualify for next stage." Crucially, this requires the Commission to halt the current progression toward the main examination until the list is corrected.

This ruling acts as a major safeguard for meritorious candidates who are often trapped by administrative procedures that deny them their rightful entry into the open merit bracket. For future aspirants across Uttar Pradesh, this judgment serves as a reminder that the constitutional promise of fair competition cannot be curtailed by restrictive shortlisting mechanisms.