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2025 Supreme(Kar) 369

IN THE HIGH COURT OF KARNATAKA AT BENGALURU
S.G. PANDIT, T.M.NADAF, JJ.
Smt. Sumithra H.R., W/o Sri Raghavendra - Petitioner 
Versus 
The State Of Karnataka Department Of Women & Child Development - Respondent 
Writ Petition No.21453 of 2022 (S-KSAT)
Decided on : 17-06-2025

Advocates:
Advocate Appeared:
For the Petitioner: SRI. SHRI MURALI B.S. ADV.
For the Respondent: SRI B RAVINDRANATH, SRI MUHAMMED SHAMIL, SRI SAMEER S.N., SRI VIJAY KUMAR G BAGOJI, SRI ANATHARAM C, ADV.

Valid reservation certificates must be submitted by the application deadline to qualify for merit categories in recruitment processes.

Headnote:(A) Karnataka Scheduled Castes, Scheduled Tribes and Other Backward Classes (Reservation of Appointments, Etc.) Act, 1990 - The High Court adjudicates the non-selection of a candidate for the post of Female Supervisor based on reservation certificate validity regarding eligibility. (Paras 8-10)

Facts of the case:
The petitioner applied for the Female Supervisor post claiming reservation under category 2A but was not selected, and her eligibility was questioned due to the late acquisition of the reservation certificate (Paras 2-3).

Findings of Court:
The Selection Authority acted correctly by considering the petitioner under general merit because the reservation certificate was expired, and the subsequent certificate was obtained after the application deadline, invalidating her claim (Paras 8-10).

Issues: The key issue considered was whether the tribunal's decision regarding the validity of the caste certificate and categorization of the petitioner under general merit was appropriate (Para 7).

Ratio Decidendi: The court held that valid caste certificates must be produced by the last date for applications to qualify for reservation, echoing previous judgments on eligibility criteria and timelines (Paras 8-10).

Result: Writ petition rejected.

Table of Content
1. non-selection of the petitioner for reservation category. (Para 1 , 2)
2. court's analysis on validity and requirement of caste certificates. (Para 3 , 7 , 9)
3. arguments for considering subsequent caste certificates. (Para 4 , 10)
4. petitioner's argument centered on the validity of caste certificates for reservation. (Para 6)
5. ratio decidendi regarding eligibility and submission timelines. (Para 8)
6. rejection of the writ petition. (Para 11)

ORDER

S.G.PANDIT, J.

The petitioner, aggrieved by order dated 06.01.2022 in Application No.4890/2019 passed by the Karnataka State Administrative Tribunal at Bengaluru (for short “Tribunal”) rejecting her application, questioning her non-selection to the post of Female Supervisor in the Department of Women and Child Development is before this Court under Article 226 of the Constitution of India.

2. The brief facts of the case are that, the petitioner vide Notification dated 05.10.2016 applied for the post of Female Supervisor in the Department of Women and Child Development claiming reservation under category 2A. The petitioner was called for verification of documents and interview was conducted on 10.01.2018. The petitioner is said to have secured 45% marks. The provisional select list of Female Supervisors was published on 28.11.2018 and the name of the applicant/petitioner was not found, whereas, the names of respondents No.3 to 7 found place in the provisional select list, who were less meritorious than the petitioner. The petitioner is said to have filed her objections to the said provisional select list. However, final select list was published on 26.02.2019. Even in the final select list also, name of the petitioner was not found. The petitioner was issued with an endorsement dated 26.02.2019 (Annexure-A11) stating that the petitioner has scored less marks than the cut-off marks, determined for eligible candidates under reserved category. Questioning the said endorsement as well as non- selection of petitioner’s candidature for the post of Female Supervisor, the petitioner approached the Tribunal in Application No.4890/2019. The Tribunal, under impugned order dated 06.01.2022 rejected petitioner’s application holding that Reservation Certificate has been obtained much later than the last date prescribed, and further observed that the petitioner’s candidature was rightly considered under general merit category. Questioning the said order, the petitioner is before this Court in this writ petition.

3. Heard learned counsel Sri.B.S.Murali for petitioner, Sri.B.Ravindranath, learned AGA for respondent No.1; Sri.Muhammed Shamil, learned counsel for respondent No.2; Sri.Sameer, learned counsel for respondent No.3; Sri.Vijay Kumar G Bagoji, learned counsel for respondent No.5 and Sri.Anantharam C., learned counsel for respondent No.6. Perused the entire writ petition papers.

4. Learned counsel for the petitioner Sri.B.S.Murali would submit that action of the respondent-Selecting Authority i.e., second respondent, in not selecting the petitioner by considering her under category-2A is wholly erroneous and illegal. He submits that the petitioner had claimed reservation under category 2A. Along with the application, the petitioner had also produced Annexure-G/Caste and Income Certificate dated 26.07.2008 and subsequently, the petitioner also produced Annexure-A5/Caste and Income Certificate dated 09.01.2018 obtained subsequent to the recruitment notification. It is his submission that the Selecting Authority ought to have considered both Caste Certificates and ought to have considered petitioner’s candidature under category 2A for selection to the post of Female Supervisor in the department of Women and Child Development. Learned counsel would submit that the Tribunal failed to take note of the Certificates said to have been produced by the petitioner before the Selecting Authority. It is also the submission of the learned counsel for the petitioner that the Tribunal failed to a

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