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2026 Supreme(UK) 198

IN THE HIGH COURT OF UTTARAKHAND AT NAINITAL
RAVINDRA MAITHANI, ALOK MAHRA, JJ.
Savita Rani – Appellant
Versus
Uttarakhand Public Service Commission and Another – Respondents
Writ Petition (S/B) No. 691 of 2024
Decided On : 05-01-2026

Advocates Appeared:
For the Appellant : Bhagwat Mehra
For the Respondents: K.N. Joshi, Pankaj Miglani

Recruitment processes demand strict documentary compliance for eligibility verification like API scores; timely objections to tentative ineligibility lists mandatory; courts refrain from interfering after selection completion and appointments.

Headnote:(A) Constitution of India - Article 226 - Service law - Recruitment - Shortlisting based on Academic Performance Indicator (API) score requires submission of complete marksheets reflecting total marks obtained and maximum marks for Master's degree to verify percentage; tentative ineligibility list uploaded on website, published in newspapers, emailed to registered IDs with 15 days for objections; failure to object timely results in final ineligibility; advertisement terms binding, no relaxation of eligibility conditions post-commencement of process; courts exercise restraint post-selection completion and appointments. (Paras 2,4,6,7,8)

(B) Principles - Selection must strictly adhere to advertisement; deviation impermissible; candidate failing eligibility on cut-off date has no right to appointment, sympathy cannot override rules; eligibility cannot be altered after process begins; no interference in statutory recruitment after conclusion. (Para 7)

Facts of the case:
Candidate applied for reserved post of Assistant Professor, shortlisted on API score, submitted documents but only final year marksheet without total marks for entire Master's degree. Tentative ineligibility list dated 03.06.2024 proposed rejection; final list dated 30.09.2024 confirmed ineligibility. Claimed non-awareness due to advanced pregnancy and delivery, but no denial of email receipt despite court direction. Interviews conducted, results declared, appointments made.

Findings of Court:
Candidate failed to meet mandatory documentary requirements for API verification; adequate opportunity to object provided but not availed timely; omission to deny email affects credibility; no basis to quash lists or permit interview.

Issues: Validity of rejection for incomplete marksheet; effectiveness of notice to tentative ineligibility list; right to participate in interview and consequential benefits post-process completion.

Ratio Decidendi: Strict compliance with advertisement mandatory for document verification; opportunity for objections duly given via multiple modes; post-completion interference would unsettle selections; settled principles bar relaxation or dilution of eligibility.

Result: Writ petition dismissed. No order as to costs.

Table of Content
1. petition challenges ineligibility lists in recruitment process. (Para 1 , 2)
2. parties contend on document verification and notice adequacy. (Para 3 , 4)
3. petitioner failed timely objections despite notice. (Para 5 , 6)
4. strict adherence to advertisement terms imperative. (Para 7)
5. no interference after selection and appointments. (Para 8 , 9 , 10)

JUDGMENT :

1. By means of present petition under Article 226 of the Constitution of India, the petitioner has sought following reliefs:

(i) “To issue a writ, order or direction in the nature of certiorari quashing the impugned notification/ineligibility list dated 30.09.2024 issued by respondent no.1, in so far as it relatesto the petitioner (Sl. No. 8, Roll No. 514824);

(ii) To issue a writ, order or direction in the natureof certiorari quashing the impugned tentative ineligibility list dated 03.06.2024 issued by respondent no.1, in so far as it relates to thepetitioner (Sl. No. 6, Roll No. 514824);

(iii) To issue a writ, order or direction in the nature of mandamus commanding the respondent Commission to permit the petitioner to participate in the interview for the post of Assistant Professor (Physics), Government Degree College, pursuant to the selection in question;

(iv) To issue a writ, order or direction in the nature of mandamus commanding the respondent authorities to grant all consequential benefits to the petitioner.”

2. Brief facts, as borne out from the record, are that respondent no.1 issued an advertisement dated 04.12.2021 inviting applications for 455 posts of Assistant Professor in various Government Degree Colleges in the State of Uttarakhand. Out of these, 36 posts were for Physics, of which 22 posts were reserved for Scheduled Caste candidates. As per the advertisement, the selection process comprised short-listing on the basis of Academic Performance Indicator (API) score, followed by interview, and final selection was to be made on the basis of marks obtained in the interview. The petitioner applied online pursuant to the said advertisement and was declared successful in the short-listing result dated 13.04.2022, whereafter she was required to submit relevant documents by 04.05.2022, which she admittedly submitted. Thereafter, in June, 2024, respondent no.1 uploaded a tentative ineligibility list dated 03.06.2024, proposing rejection of certain candidates, including the petitioner. Subsequently, a final rejection list dated 30.09.2024 was published, declaring the petitioner ineligible. Hence, the present writ petition.

3. Learned counsel for the petitioner would submit that the petitioner is a domicile of Uttarakhand, belongs to the Scheduled Caste category, holds a First Division M.Sc. (Physics) degree, is UGC-NET qualified, has also qualified CSIR-JRF, UTET-I and UTET-II, and has worked as Guest Faculty in Government Degree Colleges. It is contended that the petitioner’s candidature was rejected on a hyper- technical and flimsy ground, namely, that the marksheet of the Master’s degree did not explicitly mention total marks obtained and maximum marks, although the percentage and division were clearly reflected. It is further submitted that the tentative ineligibility list dated 03.06.2024 mentioned only roll numbers and not the names of candidates, and was neither properly published nor effectively communicated, thereby depriving the petitioner of a meaningful opportunity to submit objections. The petitioner further submits that during the relevant period she was in an advanced stage of pregnancy, delivered a child on 15.09.2024, and thus could not become aware of the tentative ineligibility list.

4. Per contra, learned counsel for respondent no.1 submits that under Clause 4(1) read with Table 3(B) of the advertisement, API scores are strictly dependent on percentage of marks obtained. It is submitted that the petitioner submitted only the final year marksheet of M.Sc., without producing documents reflecting total marks obtained and maximum marks

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