1. Dispute regarding cadre allocation in the Indian Forest Service — eligibility of a reserved category candidate who availed preliminary examination relaxation to be treated as a general merit candidate. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11 )
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2026 Supreme(SC) 16
SUPREME COURT OF INDIA
J.K. MAHESHWARI, VIJAY BISHNOI, JJ.
Union of India – Appellant
Versus
G. Kiran and Others – Respondents
Civil Appeal No. 51 of 2026 [Arising Out of Special Leave Petition (C) No. 4743 of 2020]
With
Antony S. Mariyappa – Appellant
Versus
G. Kiran and Others – Respondents
Civil Appeal No. 52 of 2026 [Arising Out of Special Leave Petition (C) No. 4067 of 2022]
Decided On : 06-01-2026
Advocates appeared:
For the Appellant(s) : Mr. Nikhil Goel, Sr. Adv. Mr. Amit Pai, AOR Mr. Aditya Bhat, Adv. Ms. Pankhuri Bhardwaj, Adv. Ms. Merin Francis, Adv. Mr. Gurmeet Singh Makker, AOR
For the Respondent(s): Mr. Jayanth Muth Raj, Sr. Adv. Mr. Vinodh Kanna B, Adv. Mr. Abhilash M R, Adv. Ms. Thilagavathi P, Adv. M/s M R Law Associates, AOR Mr. Vardhman Kaushik, AOR Mr. Dhruv Joshi, Adv. Ms. Shikha John, Adv. Mrs. P S Vijayadharni, Adv. Mr. Mayank Sharma, Adv. Mr. Arindam Sarin, Adv. Mr. Nikhil Goel, Sr. Adv. Mr. Amit Pai, AOR Mr. Aditya Bhat, Adv. Ms. Pankhuri Bhardwaj, Adv. Mr. Tathagata Dutta, Adv. Mr. Abhiyudaya Vats, Adv.
For the Appellant(s) : Mr. Nikhil Goel, Sr. Adv. Mr. Amit Pai, AOR Mr. Aditya Bhat, Adv. Ms. Pankhuri Bhardwaj, Adv. Ms. Merin Francis, Adv. Mr. Gurmeet Singh Makker, AOR
For the Respondent(s): Mr. Jayanth Muth Raj, Sr. Adv. Mr. Vinodh Kanna B, Adv. Mr. Abhilash M R, Adv. Ms. Thilagavathi P, Adv. M/s M R Law Associates, AOR Mr. Vardhman Kaushik, AOR Mr. Dhruv Joshi, Adv. Ms. Shikha John, Adv. Mrs. P S Vijayadharni, Adv. Mr. Mayank Sharma, Adv. Mr. Arindam Sarin, Adv. Mr. Nikhil Goel, Sr. Adv. Mr. Amit Pai, AOR Mr. Aditya Bhat, Adv. Ms. Pankhuri Bhardwaj, Adv. Mr. Tathagata Dutta, Adv. Mr. Abhiyudaya Vats, Adv.
IMPORTANT POINT
Reservation – For allocation of unreserved vacancy to a candidate of reserved category, selection must be on ‘General Standard’ without availing any ‘Relaxed Standard’ in either eligibility or selection criteria – In case any ‘Relaxed Standard’ has been availed by him, his allocation of cadre would be as per his merit and preference against vacancy of his category.
Headnote:
Service Law – Reservation – Indian Forest Service – [Rules, 1, 13, 14 and 17 of UPSC Exam Rules, 2013] – For allocation of unreserved vacancy to a candidate of reserved category, selection must be on ‘General Standard’ without availing any ‘Relaxed Standard’ in either eligibility or selection criteria – In case any ‘Relaxed Standard’ has been availed by him, his allocation of cadre would be as per his merit and preference against vacancy of his category – If a reserved category candidate takes benefit of relaxation though at initial stage, it will effectively amount to taking relaxation even at final stage of selection process because without giving relaxation to him, he was not in a position to participate in Main examination and to set forth his claim of cadre allocation – Respondent No. 1, having availed benefit of “Relaxed Standard” in Preliminary Examination, cannot be treated as a candidate selected on “General Standard” – Consequently, he is not entitled to be allocated against “General Insider” vacancy in Karnataka Cadre in place of Respondent No. 3. (Paras 24, 32, 38 and 39)
Facts of the case:
Dispute in the present appeals is regarding claim of a reserved category candidate i.e., Respondent No. 1, who availed relaxation in Preliminary Examination but was placed higher in merit than unreserved candidate i.e., Respondent No. 3 in the final merit list based on total marks awarded in Main Examination (Written) and Personality Test, to be treated as a General merit candidate for the purpose of cadre allocation against a General Insider vacancy for State of Karnataka in the Indian Forest Service (‘IFS’).
The question that falls for consideration is whether a reserved category candidate who availed relaxation while qualifying Preliminary Examination, though secured more marks than cut-off of General Category candidate in Main Examination and Interview for personality test and secured place in final merit list, can be considered as ‘Insider General’ candidate for cadre allocation against an unreserved vacancy?
Findings of Court:
The impugned final judgment and order dated 06.08.2019 passed by High Court of Karnataka at Bengaluru in Writ Petition No. 54254 of 2016 (S-CAT) connected with Writ Petition No. 18947 of 2016 (S-CAT), affirming order of the Central Administrative Tribunal, Bangalore Bench dated 15.03.2016 in O.A. No. 170/00239/2015, are hereby set aside. Notification dated 13.03.2015 issued by MoEFCC insofar allocating Karnataka Cadre to Respondent No. 3 and Tamil Nadu Cadre to Respondent No. 1 is upheld as correct in eyes of law and without any alteration.
Result : Appeals allowed.
Judgement Key Points
Certainly. Based on the provided legal document, here are the key points:
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The core issue revolves around whether a reserved category candidate who avails relaxation in eligibility criteria during examinations can be considered for unreserved vacancies if they perform better in subsequent stages (!) (!) .
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The examination process involves two tiers: Preliminary Examination (screening) and Main Examination with Interview. Qualification in the Preliminary Examination is mandatory to participate in the Main Examination, but marks obtained in the Preliminary are not counted toward final merit (!) (!) (!) (!) .
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The rules specify that relaxation or concessions in eligibility or selection criteria, if availed at any stage of the examination, disqualify a candidate from claiming eligibility for unreserved (general) vacancies under the ‘General Standard’ (!) (!) (!) .
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The relevant policy states that a reserved category candidate selected on ‘general standards’ is eligible for unreserved vacancies if they are not lower in rank than other general candidates. However, if a candidate has availed relaxation at any stage, they cannot be considered for unreserved vacancies (!) (!) (!) .
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The Court emphasizes that the benefit of relaxation in the Preliminary Examination, which is a screening stage, is an incident of reservation and cannot be used to claim eligibility for unreserved vacancies later in the process, even if the candidate performs better in subsequent stages (!) (!) .
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The judgment clarifies that candidates who have utilized relaxation or concessions in eligibility or selection criteria are to be considered only against their reserved category vacancies and cannot be adjusted against unreserved vacancies, regardless of their performance in subsequent stages (!) (!) .
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The Court underscores the importance of the intent behind the rules and policies, which is to ensure that candidates claiming reservation benefits do not gain an unfair advantage in claiming unreserved vacancies after availing relaxation at any examination stage (!) (!) .
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The final ruling affirms that the allocation of cadre must adhere to the rules, and a candidate who has availed relaxation in the preliminary stage cannot be treated as a candidate selected on ‘general standards’ for unreserved vacancies. Consequently, the allocation of the Karnataka Cadre to Respondent No. 3 is upheld, and Respondent No. 1's claim to the unreserved vacancy is rejected (!) (!) .
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The appeals are allowed, and the previous judgments favoring Respondent No. 1 are set aside. The notification allocating the cadre is maintained as lawful (!) .
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The judgment emphasizes the importance of applying the rules and policies consistently and that relaxation benefits at any stage of the examination process are deemed an incident of reservation, disqualifying the candidate from claiming unreserved vacancies later (!) (!) .
If you need further clarification or assistance with specific legal implications, please let me know.
Legal Category Hierarchy
Table of Contents
2. Whether relaxation in a screening-only preliminary examination precludes a reserved category candidate from being considered for an unreserved vacancy based on final merit in subsequent stages. (Para 12 , 13 , 14 , 15 , 16 )
3. The preliminary examination is an integral stage of the selection process; availing relaxation at any stage precludes adjustment against unreserved vacancies under the applicable rules and policy. (Para 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36 , 38 )
4. A reserved category candidate availing relaxation in eligibility or selection criteria at any stage of the examination cannot be treated as selected on general standards. (Para 21 , 22 , 24 , 27 , 28 , 29 , 36 )
5. Appeals allowed — impugned judgments set aside — allocation of the general insider vacancy to the general category candidate upheld. (Para 37 , 39 , 40 )
6. Does availing relaxation in a preliminary screening examination preclude a reserved category candidate from being treated as a general merit candidate for vacancy allocation?
Yes. The court held that the preliminary examination is an integral stage of the selection process. Availing relaxation at any stage, including the screening stage, means the candidate is not selected on general standards and cannot be adjusted against unreserved vacancies. (Para 21 , 22 , 27 , 29 , 36 )
7. How is the phrase at any stage of examination interpreted regarding relaxations for reserved category candidates?
It is interpreted broadly to include all tiers of the selection process. If a candidate resorts to any relaxation or concession in eligibility or selection criteria at any stage, they are ineligible for adjustment against unreserved vacancies. (Para 21 , 22 , 27 , 29 )
8. Can high marks in the main examination and interview override a relaxation availed during the preliminary examination for the purpose of general category allocation?
No. Even if a candidate surpasses general standards in subsequent stages, the initial relaxation used to qualify for those stages prevents them from being classified as a candidate selected on general standards. (Para 26 , 36 )
JUDGMENT :
J.K. MAHESHWARI J.
1. Leave granted.
2. Assailing the final judgment and order dated 06.08.2019 passed in Writ Petition No. 18947 of 2016 (S-CAT) connected with Writ Petition No. 54254 of 2016 (S-CAT) by the High Court of Karnataka at Bengaluru (hereinafter referred to as ‘High Court’), the appellants have filed these appeals. For the sake of brevity, we will refer to the parties as per their status in Civil Appeal arising out of Special Leave Petition (C) No. 4743 of 2020.
3. The dispute in the present appeals is regarding the claim of a reserved category candidate i.e., Respondent No. 1, who availed relaxation in the Preliminary Examination but was placed higher in merit than the unreserved candidate i.e., Respondent No. 3 in the final merit list based on total marks awarded in Main Examination (Written) and Personality Test, to be treated as a General merit candidate for the purpose of cadre allocation against a General Insider vacancy for State of Karnataka in the Indian Forest Service (hereinafter referred to as ‘IFS’).
4. Being aggrieved by the notification dated 13.03.2015 issued by the Ministry of Environment, Forests and Climate Change (hereinafter referred to as ‘MoEFCC’) allocating Tamil Nadu Cadre to Respondent No. 1 instead of Karnataka, Respondent No. 1 preferred an Original Application No. 170/239 of 2015 (hereinafter referred to as ‘OA’) before the Central Administrative Tribunal, Bangalore Bench (hereinafter referred to as ‘Tribunal’) and vide order dated 15.03.2016, the Tribunal allowed the Original Application holding that a meritorious Scheduled Caste (hereinafter referred to as ‘SC’) candidate cannot be denied allocation against a General vacancy solely on the ground of availing relaxation in the SC cut-off marks at the stage of Preliminary Examination. The Tribunal directed to allocate the General Insider vacancy in the State of Karnataka to Respondent No. 1. Being aggrieved by the said order, WP No. 18947 of 2016 (S-CAT) was filed by Respondent No. 3 (who was allocated the General insider vacancy) and WP No. 54254 of 2016 (S-CAT) was filed by the Union of India (hereinafter referred to as ‘UOI’), which came to be dismissed by the common impugned order of the High Court, affirming the view of the Tribunal. Hence, the present appeals.
FACTUAL MATRIX
5. Prequel to the present litigation, the MoEFCC issued Notification No. 17011/01/2013-IFS-II dated 05.03.2013 publishing ‘The Rules for a competitive examination to be held by the Union Public Service Commission in 2013’ (hereinafter referred to as ‘Exam Rules, 2013’) for the purpose of filling vacancies in the Indian Forest Service.
6. Respondent No. 1, belongs to SC category and Respondent No. 3 belongs to General category. Both appeared for the Preliminary Examination in the year 2013. As per Exam Rules, 2013, the selection process for IFS involved following two tiers: (i) the Civil Services (Preliminary) Examination for purpose of screening and (ii) the Indian Forest Service (Main) Examination followed by an Interview for personality test.
7. It is undisputed that in the Preliminary Examination, the cut-off to qualify by General Category candidates was 267 and the cut-off to qualify by SC category candidates was 233. Respondent No. 1 secured 247.18 marks, which was below the cut-off to qualify as General category candidate, however, declared qualified for the Main Examination availing the relaxed cut-off applicable to SC candidates. Simultaneously, Respondent No. 3 secured 270.68 marks in the Preliminary Exam and qualified for the Main Examination (Written) as the said score was above the cut-off for General category. The details of the marks obtained has been tabulated for ready reference as under:
| Name of Candidate | Category (as availed for purpose of Preliminary Exam) | Qualifying Marks (for purpose of Preliminary Exam) | Marks Obtained in the Preliminary Exam |
| G. Kiran [Respondent No. 1] | SC | 233 | 247.1 |
