1. Challenge to non-inclusion of petitioner's name in selection list under EWS quota in Group-I recruitment Notification. (Para 1 )
Back
Next 
2026 Supreme(Telangana) 340
IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
K.Sarath, J.
Mannem Jhansi - Petitioner
Versus
The State of Telangana, rep. by its Chief Secretary, General Administration Department and others - Respondents
Writ Petition No.30845 of 2025
Decided On : 06-03-2026
Important Points
Candidates must fulfill all eligibility criteria and upload required documents by the prescribed cut-off date in recruitment notifications. Post-facto submission of reservation certificates after the merit list is published is impermissible unless specifically allowed, as it violates the principles of equality and strict adherence to advertisement terms.
Subject
Administrative Law - Service Law
Act Referred
Headnote
(A) Service Law - Public Employment - Recruitment - Economically Weaker Sections (EWS) reservation - Compliance with notification terms - Requirement of producing income certificate prior to application - Candidate claiming reservation but failing to upload the requisite certificate at the time of submission - Submission of certificate during later stages of verification - Whether such a claim is maintainable. (Paras 12-18)
(B) Administrative Law - Principles of Recruitment - Strict adherence to the terms and conditions of the advertisement - Relaxation of criteria - Not permissible unless specifically reserved in rules or the advertisement - No candidate can claim a legal right for reconsideration by submitting a fresh or rectified certificate after the cut-off date - Eligibility must crystallize before the prescribed date. (Paras 20-24)
Facts of the case:
A candidate applied for a government service recruitment under the EWS quota. While the candidate indicated the claim for reservation in the application form, the requisite income certificate was not uploaded as mandated by the recruitment notification. The candidate later produced a manually issued income certificate for the relevant financial year during the certificate verification stage, which occurred after the publication of the merit list.
Findings of Court:
The court found that the notification explicitly required candidates to upload all required certificates during the application process. Although the mode of issuance (manual versus digital) was not a disqualifying factor, the fact that the certificate was obtained and submitted only after the merit list was declared indicated that the candidate did not possess the requisite eligibility at the time of application.
Issues: Whether the failure to upload the EWS certificate during the application process, despite subsequent submission during document verification, entitles the candidate to be considered under the reserved category.
Ratio Decidendi: Eligibility for reservation is crystallized only when the candidate possesses the requisite certificate before the prescribed cut-off date. All appointments to public office must be made in conformity with the principle of equality, requiring strict adherence to the stipulated selection procedure and advertisement terms. Post-facto submission of eligibility documents is impermissible as it would grant an unfair advantage and violate the mandate of equality in public recruitment.
Result: Writ petition is dismissed as devoid of merits.
(B) Administrative Law - Principles of Recruitment - Strict adherence to the terms and conditions of the advertisement - Relaxation of criteria - Not permissible unless specifically reserved in rules or the advertisement - No candidate can claim a legal right for reconsideration by submitting a fresh or rectified certificate after the cut-off date - Eligibility must crystallize before the prescribed date. (Paras 20-24)
Facts of the case:
A candidate applied for a government service recruitment under the EWS quota. While the candidate indicated the claim for reservation in the application form, the requisite income certificate was not uploaded as mandated by the recruitment notification. The candidate later produced a manually issued income certificate for the relevant financial year during the certificate verification stage, which occurred after the publication of the merit list.
Findings of Court:
The court found that the notification explicitly required candidates to upload all required certificates during the application process. Although the mode of issuance (manual versus digital) was not a disqualifying factor, the fact that the certificate was obtained and submitted only after the merit list was declared indicated that the candidate did not possess the requisite eligibility at the time of application.
Issues: Whether the failure to upload the EWS certificate during the application process, despite subsequent submission during document verification, entitles the candidate to be considered under the reserved category.
Ratio Decidendi: Eligibility for reservation is crystallized only when the candidate possesses the requisite certificate before the prescribed cut-off date. All appointments to public office must be made in conformity with the principle of equality, requiring strict adherence to the stipulated selection procedure and advertisement terms. Post-facto submission of eligibility documents is impermissible as it would grant an unfair advantage and violate the mandate of equality in public recruitment.
Result: Writ petition is dismissed as devoid of merits.
Legal Category Hierarchy
-
administrative law
- recruitment and selection
- conditions in recruitment notification
- judicial review of selection process
- practice and procedure
- constitutional law
Advocates Appeared:
For the Petitioner: Sri M.Surender Rao Learned Senior Counsel appearing for Sri Rama Rao Kilaru, learned Counsel
For the Respondent: Smt.M.Shalini, Learned Government Pleader, For Services-II, Sri P.S.Raja Shekar Learned Standing Counsel for
For the Petitioner: Sri M.Surender Rao Learned Senior Counsel appearing for Sri Rama Rao Kilaru, learned Counsel
For the Respondent: Smt.M.Shalini, Learned Government Pleader, For Services-II, Sri P.S.Raja Shekar Learned Standing Counsel for
Table of Contents
2. Petitioner claimed EWS certificate was valid; respondents contended petitioner failed to upload EWS certificate with application as per Notification. (Para 3 , 5 )
3. Petitioner did not possess or upload EWS certificate for relevant financial year at time of application, obtaining it only after merit list. (Para 18 , 19 )
4. A candidate must possess and upload required EWS certificate by cut-off date; subsequent certificate cannot cure ineligibility. (Para 20 , 21 , 22 , 23 , 24 )
5. Writ petition dismissed for lack of merits; no order as to costs. Pending misc. petitions closed. (Para 25 )
6. When must an EWS certificate be obtained for a recruitment process?
The EWS certificate must be obtained and uploaded before the application cut-off date; a certificate obtained after merit declaration is invalid. (Para 18 , 20 , 21 )
7. Can an EWS certificate submitted at certificate verification stage cure non-submission at application stage?
No. An EWS certificate submitted only at certificate verification, after merit list publication, cannot cure the initial failure to upload it when applying. (Para 18 , 22 , 23 , 24 )
8. Must recruitment conditions in an advertisement be strictly adhered to?
Yes. Conditions in an advertisement must be scrupulously maintained; no relaxation is permitted unless the power of relaxation is specifically reserved. (Para 22 , 23 )
9. What is the effect of failing to upload a required document with the application form?
Failing to upload a required document, such as an EWS certificate, with the application form renders the candidature ineligible for that category. (Para 14 , 15 , 16 , 17 , 24 )
10. Is a certificate obtained after the selection process over valid for EWS claim?
No. A certificate submitted after the selection process is over, even if genuine, cannot be considered for claiming EWS reservation benefits. (Para 18 , 20 , 21 )
ORDER :
K.Sarath, J.
1. This writ petition is filed questioning the action of the respondent No.2 in not including the petitioner’s name in the selection list under Economically Weaker Section quota in pursuance to the Group-I Notification vide Notification No.2/2024 dated 19.02.2024 and inclusion less meritorious candidates as illegal and arbitrary and declare that the petitioner is entitled to be selected and appointed to the posts in one of the Grade-I service based on her merit/rank/marks as an E.W.S candidate.
2. Heard Sri M. Surender Rao, learned Senior Counsel for Sri Rama Rao Kilaru, learned counsel for the petitioner, Smt M. Shalini, learned Government Pleader for Services-II for the respondent No.1 and Sri P.S.Raja Sekhar, learned Standing Counsel for the respondent No.2.
CONTENTIONS OF THE PETITIONER
3. Learned Senior Counsel for the petitioner submits that the petitioner is a Post Graduate and belongs to O.C Category and Economically Weaker Section (for brevity ‘EWS’). Pursuant to the Notification No.4/2022 dated 26.04.2022 issued by the respondent No.2 inviting online applications from the qualified applicants to the post of Group-I services in the State of Telangana, the petitioner made online application under reservation of Economically Weaker Sections and uploaded her certificate mentioned at Clause XV of sub-Para 10 of para IV apart from other certificates. She has appeared for preliminary test held on 16.10.2022 and the same was cancelled due to leakage of paper. On instructions of the respondent No.2, the petitioner has again appeared for the preliminary test. Subsequently, the respondent No.2 has cancelled Notification No.4/2022 and issued fresh Notification No.2/2024 dated 19.02.2024. In response to the same the petitioner made online application under Economically Weaker Sections, appeared for preliminary test and qualified for main examination and in the main examination secured a general rank of 418 and secured 458.500 out of 900 marks. The respondent No.2 issued Notification for verification of certificates and the name of the petitioner was figured in the said Notification and the petitioner has submitted an attestation form on 15.04.2025 and also submitted basic information data (checklist) on 16.04.2025 and the acknowledgment indicated that she has submitted all the certificates.
4. Learned Senior Counsel for the petitioner further submits that the respondent No.2 published a result notification on its website on 24.09.2025 containing the Hall Ticket numbers of 562 candidates, but the Hall Ticket number of petitioner does not figure in the said Notification. He submits that as the petitioner applied for Group-I Services under E.W.S. reservation, qualified for the certificates verification and produced relevant Income/E.W.S. certificate at the time of verification, she is entitled to be considered for appointment in preference to the candidates who seems lesser marks or merit and non- consideration of her candidature in the selection process after certificate verification stage as illegal and arbitrary and requested to allow the writ petition.
CONTENTIONS OF THE RESPONDENTS
5. Learned Standing Counsel for the respondent No.2 basing on the counter submits that as per the impugned recruitment Notification No.2/2024, the Income Certificate for the financial year prior to the year of application issued by the revenue authorities not below the rank of Tahsildar working under Telangana Government in the name of the candidate with total income of the family below 8 lakhs for claiming EWS reservation was for the year 2022-23 and valid for the year 2023-24, but the petitioner has submitted EWS Certificate issued for the year 2021-2022 obtained thorough Mee-Seva and further she has submitted manually issued EWS Certificate for the year 2022-2023 at the time of certificate verification, which are not in accordance with the Government orders and failed to submit appropriate certificate for EWS category as prescribed in
