Candidates availing relaxed standards under the ME category cannot migrate to other reserved categories, affirming the principle against double reservation in public employment.

JUDGMENT :

1. In the present batch of writ petitions, the core controversy requiring adjudication predominantly pertains to the legality and validity of the impugned result dated 17.12.2024 declared by the respondents in pursuance to the examination conducted in furtherance to the advertisement dated 20.06.2023 whereby the respondent-Board had invited applications for the post of Junior Accountant and Tehsil Revenue Accountant. Although ancillary issues are also raised, the principal question of law revolves around the legality and validity of the impugned result whereby the respondents have included the candidates of Ministerial Employees (hereinafter referred to as ‘ME category’) by treating their candidature in the SC, ST or General category. Having regard to the commonality of issues both in law and in fact, and upon consent being recorded from the learned counsel appearing for the respective parties, this Court deems it appropriate to treat SBCWP NO. 278/2025 titled as Mohit Soni and Ors. Vs. State of Rajasthan and Ors. as the lead petition for the purposes of this adjudication.

2. It is, however, considered apposite to clarify at the outset that while there may exist factual variances among the individual petitions constituting the present batch, such discrepancies are confined solely to the narrative factual matrices peculiar to each case. They do not impinge upon or detract from the common questions of law which fall for consideration before this Court. Accordingly, the judgment rendered herein shall apply to all the writ petitions connected and heard together with the lead matter, on a mutatis mutandis basis, subject to necessary adaptation to the individual factual contexts where required.

3. Before proceeding to examine the present petitions on their merits, it is imperative to first delineate the foundational facts and the core issues arising therein. A precise appreciation of the factual matrix and procedural background is essential to contextualize the grievances of the petitioners and the legal questions that fall for adjudication. The salient aspects of the petitions are, therefore, summarized as under:

FACTUAL NARRATIVE:

4. On 21.09.2022 the respondent-Board issued an advertisement (advertisement no. 9/2022) inviting applications from eligible candidates for the Common Eligibility Test – Graduation Level Examination, 2022 (hereinafter referred to as 'CET'). Consecutively, on 20.06.2023 the respondent-Board issued an advertisement (advertisement no. 2/2023) for recruitment to 5190 posts of Junior Accountant and 198 posts of Tehsil Revenue Accountant. Out of the advertised posts, 12.5% of the vacancies under the non-TSP (Tribal Sub-Plan) area, and three (03) posts under the TSP area, were earmarked for reservation in favor of candidates falling under the ME category.

5. After the receipt of application forms, the respondents, on 06.12.2023, declared the cut-off marks based on CET scores. Distinct cutoff marks were prescribed for different categories, namely, General, Economically Weaker Sections (EWS), Scheduled Castes (SC), Scheduled Tribes (ST), Other Backward Classes (OBC), Most Backward Classes (MBC), and special categories including the ME category. Notably, the cutoff marks under the ME category were determined at 31.8792, which was substantially lower than the cutoffs prescribed for the other categories.

6. Thereafter, on 20.12.2023, the respondent-Board issued the list of candidates eligible to appear for the Main Examination for the posts of Junior Accountant and Tehsil Revenue Accountant. The said Main Examination was conducted on 11.02.2024. Subsequent thereto, on 27.06.2024, the respondents declared the category-wise cutoffs and called candidates, twice the number of advertised vacancies, for the process of document verification. The cutoffs declared for various categories were illustratively as follows: SC (General) – 447.46, SC (Female) – 319.30, OBC (General) – 555.61, OBC (Female) – 461.30, and for the