Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(SC) 380

SUPREME COURT OF INDIA
Manoj Misra, Prasanna B. Varale, JJ.
Poonam Dwivedi & Ors. – Petitioner
Versus
State of U.P. & Ors. – Respondents
Civil Appeal No. 4342-4343 of 2026 (@ SLP (C) No.4001-4002 of 2023) With Civil Appeal No. 4344 of 2026 (@ SLP (C) No. 20256 of 2023 With Civil Appeal No. 4345-4346 of 2026 (@ SLP (C) No. 22042-22043 of 2023)
Decided On : 10-04-2026

Advocates appeared:
For the Petitioner(s): Ms. Parul Shukla, AOR Mr. Alok Mishra, Adv. Ms. Shubhangi Pandey, Adv. Mr. Gladson Rodrigues, Adv. Mr. Saday Mondol, Adv. Ms. Keesha Kumar, Adv. Ms. Vanya Gupta, AOR Mr. Tarun Kumar Sobti, Adv.
For the Respondent(s): Mr. Talha Abdul Rahman, AOR Mr. Sudhanshu Tewari, Adv. Mr. Faizan Ahmed, Adv. Mr. Shuktiz Sinha, Adv. Mr. Sarvesh Singh Baghel, AOR Ms. Shivranjani Ralawata, Adv. Ms. Pooja Singh, Adv. Dr. Vinod Kumar Tewari, AOR Mr. Pramod Tiwari, Adv. Mr. Vivek Tiwari, Adv. Ms. Priyanka Dubey, Adv. Mr. Manindra Dubey, Adv. Ms. Saumya Mishra, Adv. Mr. Jitesh Sharma, Adv. Mr. Ramnesh Verma, Adv.

The court held that EWS certificates must be valid for the relevant financial year and adhere to the prescribed format; any deviation renders them invalid for claiming reservation benefits.

Headnote:(A) Uttar Pradesh Public Services (Reservation for Economically Weaker Sections) Act, 2020 - Admissibility of EWS certificate - Certificates submitted did not correspond to the relevant financial year as required by advertisement - Appellants' certificates were invalid due to incorrect dates and failure to meet prescribed format - The restriction in issuing certificates is justified as it adheres to legislative framework for valid reservation claims. (Paras 19, 25 - 27)

(B) Recruitment and eligibility - Importance of proper documentation in public recruitment - Incorrect or misleading information may lead to rejection of candidature. (Paras 28)

Facts of the case:
Appellants sought reservation under the EWS category for health worker positions but were denied appointment due to issues with their EWS certificates, which were not valid as per the requirements outlined in the advertisement.

Findings of Court:
Court concurred with the findings of the High Court that the certificates failed to meet the criteria set forth, thereby justifying the rejection of the appellants’ claims for reservation.

Issues: The primary issue was the validity of the EWS certificates submitted by the appellants and whether they complied with the advertisement's requirements.

Ratio Decidendi: The court ruled that certificates must be valid for the correct financial year as per legislation and any deviation negates eligibility for reservation.

Result: Appeals dismissed.

Judgement Key Points

Key Points: - The UP EWS Act requires certificates for the financial year prior to the year of application; certificates not so dated are invalid (!) (!) (!) . - Certificates issued before the relevant financial year or not conforming to the prescribed format render candidates ineligible for EWS reservation (!) (!) . - The Division Benches held that erroneous or non-compliant EWS certificates justify rejecting the EWS claims in recruitment, and appeals were dismissed, with no order as to costs (!) (!) . - The High Court found that confusion existed due to advertisement and certificate wording; the Supreme Court ultimately upheld rejection of certificates not valid for the correct financial year (!) (!) . - The Court emphasized that certificates should be issued by eligible authorities and must reflect income/assets for the correct financial year, failing which candidatures may not be considered for EWS (!) (!) . - The Court noted that applicants who relied on certificates issued in error due to state guidelines faced adverse impact, but still upheld the rejection due to strict compliance requirements (!) (!) . - The matter highlights the need for clear state guidance to align certificates with advertisement terms to avoid eligibility disputes (!) .

What is the validity requirement for EWS certificates in relation to the relevant financial year for reservation in public recruitment?

What is the impact of issuing EWS certificates with incorrect dates or non-conforming formats on eligibility for reservation?

What is the court's stance on whether discrepancies in EWS certificates can justify rejection of otherwise eligible candidates in recruitment?

Table of Content
1. issuance of ews certificates and application dates. (Para 2 , 3 , 4 , 5 , 6 , 7)
2. applicants' claims and grounds for challenge. (Para 8 , 9 , 10)
3. court's observations on confusion and validity of ews certificates. (Para 12 , 15)
4. requirement of compliance with advertisement provisions. (Para 19 , 20 , 21)
5. validity of certificate and legal standards for ews. (Para 26 , 27)
6. final dismissal of appeals and order for costs. (Para 28 , 29)

JUDGMENT :

MANOJ MISRA, J.

1. Leave granted.

2. These appeals impugn a common judgment and order of the High Court of Judicature at Allahabad, Lucknow Bench, Lucknow¹[High Court] dated 09.01.2023 in Special Appeal Nos. 464, 465, 466 and 467 of 2022 preferred against an order of Single Judge of the High Court dated 19.10.2022 in Writ A No. 5392 of 2022 (Poonam Dwivedi v. State of U.P. and others); Writ A No.6974 of 2022 (Divya Awasthi v. State of U.P. and others); Writ A No. 6911 of 2022 (Archana Saxena v. State of U.P. and others); Writ A No. 5264 of 2022 (Komal v. State of U.P. and others) and Writ A No. 6357 of 2022 (Shanu Tiwari v. State of U.P. and others).

3. On 15.12.2021, the Uttar Pradesh Subordinate Service Selection Commission²[Commission] issued an advertisement inviting applications for filling up 9212 posts of Health Workers (Female). Ten per cent posts i.e., 921 posts were reserved for EWS³[Economically Weaker Section.] Category. Last date for submitting the application was 05.01.2022.

4. Pursuant to the invite, the appellants applied under the EWS category for appointment to the post of Health Worker (Female).

5. Clause 8.3 of the advertisement provided:

“The candidates seeking reservation/relaxation in age limit, will have to submit a caste certificate/ reservation certificate, which has been issued till the last date of application or last date of advertisement in prescribed proforma printed in the appendix of detailed advertisement and available on the website issued by the competent officer in support of reservation category and they should produce the said certificate before the Commission when required.”

6. The prescribed form in which the certificate had to be submitted by a candidate for securing reservation in EWS category is as follows:

Form-I Government of Uttar Pradesh
Name of office:

Certificate with regard to income and assets to be submitted by the member of the Economically Weaker Section
Certificate No.			Date:
Valid for the financial year……..
It is certified that Shri/Smt/Kumari….. Son/Wife/Daughter of is a permanent Resident of Village/Kasba………, Post Office……. Police Station ………. Tehsil………. District……….. State, Pin Code…………. whose attested photograph given below, is a member of economically weaker section because the total income of his family is below Rs. 8,00,000/-(Rupees eight lakh) in the financial year…… Any of the following properties are not in the ownership of his family.
	(i). More than 5 (five) acre cultivable agricultural land) (ii). Plot or one thousand square feet or more than area; (iii). Residential plot or more than 100 square yards within the notified municipality.
2. Shri/Smt./Kumari is a member of caste, which is not notified in Scheduled Caste, Scheduled Tribe and any other backward class.

		Signature (With office seal) Full Name: Designation: District Magistrate/Additional District Magistrate/City Magistrate/Pargana Magistrate/Tehsildar”

7. Thus, the following dates are crucial, that is, the date of advertisement, which is, 15.12.2021; and the last date of submission of application, which is, 05.01.2022. Taking into consideration the terms of the advertisement and those dates, an EWS certificate must:

(b) be dated

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2026 Supreme(SC) 380

The court held that EWS certificates must be valid for the relevant financial year and adhere to the prescribed format; any deviation renders them invalid for claiming reservation benefits.

What is the validity requirement for EWS certificates in relation to the relevant financial year for reservation in public recruitment?

What is the impact of issuing EWS certificates with incorrect dates or non-conforming formats on eligibility for reservation?

What is the court's stance on whether discrepancies in EWS certificates can justify rejection of otherwise eligible candidates in recruitment?

Cases Referred (2)

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