Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Ori) 54

IN THE HIGH COURT OF ORISSA AT CUTTACK
SANJEEB K. PANIGRAHI, J.
Nitosh Kumar Das – Appellant
Versus
State of Odisha and Another – Respondents
W.P. (C) No. 35478 of 2025
Decided On : 15-01-2026

Advocates Appeared:
For the Appellant : Biplaba P.B. Bahali
For the Respondents: Sonak Mishra, D.P. Nanda, Sarita Moharana

A candidate from a reserved category must meet unreserved eligibility criteria without claiming age relaxation when applying for unreserved posts unless expressly provided by recruitment rules or advertisement.

Headnote:(A) Constitution of India, 1950 - Articles 226 and 227 - Recruitment process for Management Trainee - Petitioner challenged the rejection of his application based on over-age despite fulfilling eligibility; Court found no vacancy for SEBC category and ruled that absence of enabling rules precludes age relaxation when applying against unreserved posts - Migration to unreserved category requires express statutory sanction. (Paras 1, 4, 10, 14)

(B) Eligibility under Recruitment Rules - Candidates from reserved categories applying for unreserved posts must meet all unreserved eligibility conditions, including age limits. (Paras 8, 11)

(C) Equal Opportunity - Granting age relaxation in absence of statutory provision leads to unconstitutional discrimination, violating Articles 14 and 16. (Paras 13, 14)

Table of Content
1. petitioner's application eligibility and recruitment details. (Para 1 , 2)
2. petitioner's arguments on eligibility and age relaxation. (Para 3 , 4)
3. court analysis on age eligibility and recruitment rules. (Para 5 , 6 , 7 , 8 , 9 , 10 , 11 , 12 , 13)
4. predominant legal standards on migration between categories. (Para 14)
5. final dismissal of the writ petition. (Para 15)

JUDGMENT :

SANJEEB K. PANIGRAHI, J.

1. The Petitioner instituted the present Writ Petition filed under Article 226 and 227 of the Constitution of India, 1950, challenging the action of the Opposite Parties in refusing to accept the Petitioner’s application for participation in the recruitment process for the post of Management Trainee Human Resource, MT(HR) pursuant to Advertisement No. OHPC: HQ: HRD: RECTT:02/2025, dated- 07.11.2025, despite the Petitioner fulfilling all the prescribed eligibility criteria as stipulated in the said advertisement.

I. FACTUAL MATRIX OF THE CASE

2. The brief facts of the case culled out from the pleadings:

(i) Opposite Party No.2, Odisha Hydro Power Corporation Ltd. (OHPCL), issued Advertisement No. OHPC: HQ: HRD: RECTT:02/2025 dated 07.11.2025, inviting applications for recruitment to the posts of Management Trainees (MTs) and Diploma Engineers Trainees (DETs) in various disciplines, for induction and subsequent deployment at different units and project sites of the Corporation.

(ii) Applications for the aforesaid posts were invited exclusively through online mode, and the relevant application link was hosted on the official website of Opposite Party No.2, namely www.ohpcltd.com The online application portal remained open from 12.11.2025 to 11.12.2025.

(iii) The advertisement, under Clause (F), clearly prescribed the age eligibility criteria, stipulating a minimum and maximum age limit of 18 to 32 years for candidates applying for the post of DETs, and 21 to 32 years for candidates applying for the post of MTs. It further provided for relaxation of the upper age limit by 5 years for candidates belonging to SC/ST/SEBC/Women categories and 10 years for candidates belonging to the PwD category, notwithstanding that no vacancy was specifically earmarked for the SEBC category.

(iv) The Petitioner, being a BBA graduate with an MBA qualification and belonging to the SEBC (reserved) category, found himself fully eligible for the post of Management Trainee (HR) under the unreserved category, in terms of the eligibility conditions stipulated in the advertisement, and accordingly submitted his application through the online portal within the stipulated time.

(v) Upon submission of the online application, an auto-generated Unique Registration Number, i.e., OHPCL25013790, was initially allotted to the Petitioner. However, subsequently, the Opposite Parties declined to accept the Petitioner’s application on the purported ground of over-age, thereby rejecting his candidature without lawful justification.

Aggrieved by the foregoing inaction of the Opposite Party No.2, the Petitioner has been constrained to file the present Writ Petition.

II. SUBMISSIONS ON BEHALF OF THE PETITIONER

3. The learned counsel for the Petitioner respectfully and earnestly made the following submissions in support of his contentions:

(i) Odisha Hydro Power Corporation Ltd. (OHPCL) issued Advertisement No. OHPC: HQ: HRD: RECTT:02/2025, dated 07.11.2025, inviting applications for recruitment to the posts of Management Trainees (MTs) and Diploma Engineer Trainees (DETs) in various disciplines.

(ii) The Petitioner is a BBA graduate with an MBA qualification and belongs to the reserved category, i.e., SEBC. In terms of the eligibility conditions, including age criteria and educational qualifications prescribed in the said advertisement, the Petitioner was fully eligible for consideration for the post of Management Trainee (HR) under the unreserved category, as the advertisement did not prohibit candidates belonging to reserved categories from competing for unreserved