Back
2026 Supreme(Gau) 1211
THE GAUHATI HIGH COURT, (HIGH COURT OF ASSAM, NAGALAND, MIZORAM AND ARUNACHAL PRADESH)
MICHAEL ZOTHANKHUMA, RAJESH MAZUMDAR, JJ.
Sameer Ranjan Das, S/o. Mukheswar Das – Appellant
Versus
Indian Oil Corporation Ltd., Represented By Its Chief General Manager and Ors. – Respondents
WA/56 of 2026
Decided On : 23-06-2026
For the Appellant : Mr. B. Baruah, Adv
For the Respondents: Mr. N. Deka, Sr. Adv., Mr. M. Gogoi, Adv., Mr. D. Nath, Sr. Government Adv., Assam, Mr. D. Das, Sr. Adv., Mr. K. Mohammad, Adv.
Recruitment terms are strictly binding on both applicants and employers. Relaxation of mandated documentation criteria by judicial order after the commencement of a selection process undermines fair competition and violates the principle of equality in public employment.
Headnote:(A) Constitution of India - Articles 14 and 16 - Public employment - Recruitment process - Binding nature of advertisement conditions - Selection must be conducted strictly in accordance with stipulated procedure - Relaxation of mandatory conditions without specific reserved power or proper public notice constitutes an impermissible deviation from the principle of equality. (Paras 19, 21, 26)
(B) Recruitment procedure - Submission of documents - Mandatory compliance with prescribed formats - Responsibility of candidate - Failure to specify caste details in the certificate as required by the advertisement constitutes a valid ground for rejection - Subsequent consideration of extraneous documents not submitted with the original application or failing to meet the prescribed format undermines the fairness of the competitive process. (Paras 12, 18, 25, 30)
Facts of the case:
A candidate applied for a technical position, but the application was rejected because the submitted caste certificate did not specify the community as required by the prescribed format in the advertisement. A judicial order subsequently directed the recruiting authority to consider a different, older document to validate the candidacy. An appeal was filed against this order by a competing candidate, asserting that the court lacked authority to permit the relaxation of strictly defined eligibility conditions after the selection process had concluded.
Findings of Court:
The court held that the recruiting authority was correct in its initial rejection due to the non-compliance with the advertisement's mandatory documentation requirements. The court further ruled that the original directed relaxation of these terms was legally unsustainable as it introduced uncertainty and unfairness into the recruitment exercise.
Issues: Whether an applicant can be allowed to retrospectively fulfill eligibility requirements through supplementary documentation not provided in the original application, and whether a court can mandate the relaxation of conditions specified in a formal recruitment advertisement.
Ratio Decidendi: The terms and conditions of a recruitment advertisement are binding on both the candidate and the authority. Once the process is initiated, strict compliance is required to ensure equality and prevent procedural chaos; judicial intervention should not allow the curing of substantive defects in documentation outside of the initial stipulated framework.
Result: Appeal allowed; impugned order set aside.
| Table of Content |
|---|
| 1. procedural history and factual context of the recruitment dispute. (Para 1 , 2 , 3 , 5 , 6 , 7 , 8 , 9 , 10) |
| 2. contention regarding adherence to prescribed format for caste certificates. (Para 4 , 11 , 12 , 13 , 14 , 15) |
| 3. strict compliance with advertisement terms and judicial interpretative limitations. (Para 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24) |
| 4. candidate's duty of due diligence in fulfilling mandatory application requirements. (Para 25 , 26 , 27 , 28 , 29 , 30) |
| 5. invalidation of directions exceeding the scope of the recruitment advertisement. (Para 31 , 32 , 33) |
JUDGMENT :
M. Zothankhuma, J.
1. Heard Mr. B. Baruah, learned counsel for the appellant. Also heard Mr. N. Deka, learned Senior Counsel assisted by Mr. M. Gogoi, learned counsel appearing for the respondent Nos. 1 & 2; Mr. D. Nath, learned Senior Government Advocate, Assam, appearing for the respondent no.3 and Mr. D. Das, learned Senior Counsel assisted by Mr. K. Mohammed, learned counsel for the respondent no. 4.
2. This is an appeal against the observations and directions made in the impugned Order dated 10.12.2025, passed by the learned Single Judge in WP(C) 62/2025, on the basis of which the writ petitioner, who is the respondent No.4 in this appeal, has been appointed to the post of Junior Engineering Assistant-IV (Production), pursuant to the Advertisement dated 20.07.2024 issued by the Indian Oil Corporation Limited (‘IOCL’ in short).
3. The grievance of the appellant is that the Caste Certificate submitted by the respondent No.4 did not specify the caste to which the respondent No.4 had belonged, so as to make him eligible for participating in the selection process. However, due to the directions passed by the learned Single Judge in the impugned order, directing the IOCL to consider whether the respondent No.4 belonged to the ‘Mali’ community, which is recognized as a Scheduled Caste in the State of Assam, in terms of the Constitution (Scheduled Tribes) Order, 1950, the respondent No.4 has thereafter been found to belong to the said community and has been made eligible for participating in the selection process. As the respondent No.4 had secured better marks in the selection process, the respondent No.4 was selected for appointment to the said post.
4. The basic case of the appellant is that as the respondent No.4 had failed to specify the particular Scheduled Caste category to which he belonged, in the Scheduled Caste Certificate submitted in terms of the Advertisement dated 20.07.2024, the respondent No.4 could not have been allowed to participate in the selection process by the learned Single Judge.
5. The facts of the case in brief are as follows:-
The advertisement for filling up the post of Junior Engineering Assistant-IV (Production) was issued on 20.07.2024 and the terms of the Advertisement dated 20.07.2024 at Clause-13(v), the SC/ST Certificate was to be submitted along with the application for appointment as per the prescribed format. The application of the respondent No.4 was rejected on 29.09.2024 by the IOCL and he was not called for interview, on account of the specific Scheduled Caste name not being mentioned in the Caste Certificate of the respondent No.4. Being aggrieved by the rejection of his candidature for the post of Junior Engineering Assistant-IV (Production) pursuant to the Advertisement dated 20.07.2024, the respondent No.4 filed WP(C) 62/2025.
6. The learned Single Judge vide the impugned Order dated 10.12.2025 disposed of WP(C) 62/2025, by holding that he did not find any error with regard to the decision taken by the IOCL, not to further consider the case of the respondent No.4 in the recruitment process. The learned Single Judge, however, went a step further and held that the Caste Certificate, as uploaded by the respondent No.4 and issued by the Office of the Deputy Commissioner, Kamrup at Amingaon, had not been disputed by the IOCL to be a fake or a forged one. The certificate submitted by the respondent
