Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Telangana) 900

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
NAMAVARAPU RAJESHWAR RAO, J.
G. Sammaiah and Others – Appellants
Versus
State of Telangana and Others – Respondents
Writ Petition Nos. 14675, 16684, 16715, 24113, 25028, 26477, 26909, 27175, 28035, 28046, 28969, 28978, 30741, 32196, 32519, 32687, 34147, 34408, 34446, 35677, 36422 of 2024, Writ Petition Nos. 4995, 9198, 9202, 9704 of 2025
Decided On : 14-10-2025

Advocates Appeared:
For the Appellants : E. Madhan Mohan Rao, M. Srinivas, J. Sudheer, Ramesh Challa, P.V. Krishnaiah, Kongara Raj Kumar, Chikkudu Prabhakar, Allika Suresh, Uma Devi Nama, V. Ravi Chandran
For the Respondents: P.S. Rajasekhar, G. Satish Reddy, B.S. Prasad, S. Goutham, Rachana Reddy, Mohammed Baseer Riyaz

The court ruled that the criteria for eligibility of sportspersons under the 2% quota must be inclusive of all merit levels, rejecting limitations imposed by specific forms or misconstrued interpretations of government orders.

Headnote:(A) Constitution of India, Articles 14, 16, and 21 - Telangana State and Subordinate Service Rules, 1996 - G.O.Ms.No.74, G.O.Ms.No.5, G.O.Ms.No.107 - Sports Policy - Writ petitions questioning interpretation and implementation of 2% sports quota - Petitioners challenged exclusion based on misconstrued criteria for meritorious sportspersons. (Paras 1-81)

(B) Legal interpretation - Forms can serve to authenticate certificates but cannot limit eligibility based on participation level; equal treatment of sportspersons emphasized. (Paras 15, 73, 79)

(C) Statutory provisions regarding recruitment reservation prioritization clearly rejected misinterpretation of G.O.s that excluded eligible candidates. (Paras 46-81)

Facts of the case:
Writ petitions filed by sportspersons seeking inclusion under the sports quota based on government orders. They participated in national competitions but were excluded due to strict interpretation of eligibility forms.

Findings of Court:
Court found the authority's interpretation erroneous; all eligible sportspersons must be considered based on merit as outlined in the G.O.s.

Issues: Main issues included the scope of eligibility under the 2% sports quota and validity of forms versus substantive rules.

Ratio Decidendi: The distinction between ‘meritorious’ and ‘outstanding’ sportspersons clarified; forms should not restrict candidates’ eligibility when the meritorious category is broader.

Result: Petitioners allowed to participate; vacated restrictions imposed by authorities.

Table of Content
1. challenge to sports quota reservation. (Para 1 , 3 , 4)
2. understanding of government orders regarding reservation. (Para 5 , 6 , 7)
3. qualifications for sports reservation outlined. (Para 8 , 9 , 10)
4. disqualification of candidates based on form requirements. (Para 11 , 12 , 15 , 17 , 19)
5. sustained arguments about the merits of sports policy. (Para 18 , 20 , 22)
6. reference to previous legal principles impacting the decision. (Para 63 , 64 , 65)

ORDER :

1. All these Writ Petitions are hereby disposed of by this Common Order, as the issue involved in these Writ petitions is identical. These Writ Petitions are filed questioning the Sports Policy of the State of Telangana with regard to interpretation and implementation of 2% Sports quota in all the recruitments to various posts.

2. Heard learned counsel for respective parties:

Sri E. Madhan Mohan Rao, learned Senior Counsel, representing Sri M. Srinivas, Sri J. Sudheer, Sri Ramesh Challa, Sri P.V. Krishnaiah, Sri Kongara Raj Kumar, Sri Chikkudu Prabhakar, Sri Allika Suresh, Smt. Uma Devi Nama, Sri V. Ravi Chandran, learned counsel for the respective petitioners.

Sri P.S. Rajasekhar, learned Standing Counsel for TGPSC, learned Additional Advocate General, Learned Government Pleader for Services-I, Sri G. Satish Reddy, learned Standing Counsel for Sports Authority of Telangana, learned counsel appearing for the respective official respondents.

Sri B.S. Prasad, learned Senior Counsel, representing Sri S. Goutham, in W.P.No.28035 of 2024 and Smt. Rachana Reddy, learned Senior Counsel, representing Sri Mohammed Baseer Riyaz in W.P.No.34408 of 2024, appearing for the respective unofficial respondents, and perused the material available on record.

3. For convenience, the facts stated in W.P.No.25028 of 2024 are discussed here under:

Learned counsel for the petitioners submits as follows:

That the petitioners are sportspersons who participated in Senior Nationals, Junior Nationals and All India University Competitions. The third respondent invited Online applications from the qualified candidates for various posts in Group-I services in the State of Telangana vide Notification No.2/2024, dated 19.02.2024 in respect of 563 posts to be filled as per Rules 22 and 22A of the Telangana State and Subordinate Service Rules, 1996 and Special Rules relating to the posts.

4. Petitioners applied for Group-I Services under 2% sports quota, where four vacancies were notified out of 563 posts, in the Notification itself in terms of G.O.Ms. No. 107, General Administration (Ser.D) Department, dated 27.07.2018(hereinafter referred to as G.O.Ms.No.107) and G.O.Ms.No.5, Youth Advancement, Tourism Culture (Sports) Department, dated 14.05.2018 (hereinafter referred to as G.O.Ms.No.5). Aggrieved by the action of the respondents in excluding them on the misconception with reference to Form-I in Annexure-III of G.O.Ms.No.74, Youth Advancement, Tourism and Culture (Sports) Department, dated 09.08.2012 (hereinafter referred to as G.O.Ms.No.74) and not considering them in terms of the said G.O.Ms.No.74, read with G.O.Ms.No.5, and G.O.Ms.No.107. Hence, this Writ Petition.

5. Paragraph No.4 of the Notification, dated 19.02.2024 deals with ‘Reservations.’ Clause 4.7 of the said paragraph stipulates that the reservation to “Meritorious Sportsperson” is applicable as per the amendments made to the State and Subordinate Service Rules, 1996 (hereinafter referred to as Rules). As per G.O.Ms.No.107, that is in Rule-2, for sub-Rule (20) and in Rule-22(i) in sub-Rule (2), for Class-D. In implementing the reservation to Meritorious Sports Person, G.O.Ms.No.05 will be followed. In the event of non-availability of eligible “Meritorious Sportspersons”, two percent (2%) reservation of posts for them stand lapsed.

6. Vide Notification, in G.O.Ms.No.107, sub-rule (20) of Rule 2 of the Rules, was amended with regard to “meritorious sportspersons.” In fact, prior to that, as per the Government policy of the then Andhra Pr