2026 Supreme(Online)(CAT) 5800

CENTRAL ADMINISTRATIVE TRIBUNAL
Manish Garg, J, Anand S Khati, MEMBER A
4232/2022
O.A. No.1880/2022 | O.A. No.1885/2022 | O.A. No.1933/2022 | O.A. No.1934/2022 | O.A. No.2051/2022 | O.A. No.3307/2022 | O.A. No.3330/2022 | O.A. No.3333/2022 | O.A. No.3382/2022 | O.A. No.3403/2022 | O.A. No.3384/2022 | O.A. No.3386/2022 | O.A. No.3387/2022

The court held that age relaxation for meritorious sportspersons under OM dated 12.11.1987 applies to all civil posts except UPSC-recruited ones, and reclassification from Group C to Group B does not defeat this entitlement.

Headnote:(A) Constitution of India, 1950 - Article 14 and Article 320 - Recruitment Rules for Physical Education Teacher (Group B Post), 2011 - Central Civil Services (Classification, Control and Appeal) Rules, 1965 - Office Memorandum dated 04.08.1980 - Office Memorandum dated 12.11.1987 - Office Memorandum dated 03.10.2013 - Office Memorandum dated 06.09.2022 - Doctrine of Purposive Interpretation - Application of principle that interpretation favourable to the beneficiary should be preferred - Reclassification of posts from Group 'C' to Group 'B' due to Pay Commission recommendations does not alter existing benefits for special categories unless specifically excluded.

(B) Service Law - Age relaxation - Meritorious Sportspersons - The benefit of age relaxation granted to meritorious sportspersons under the OM dated 12.11.1987 for appointment to 'all' Groups of Civil posts/services under the Government, except those filled through UPSC, continues to apply to posts reclassified from Group 'C' to Group 'B' - The exclusion is only for posts filled through UPSC, not for those filled through DSSSB - A subsequent corrigendum issued mid-recruitment process cannot withdraw a benefit validly extended by an advertisement and an initial corrigendum, as it amounts to changing the rules of the game midway and is arbitrary.

(C) Evidence - Interpretation of Documents - An Office Memorandum is a statutory instrument; a consolidated guideline is a compilation of excerpts for convenience, not a complete code - When the term 'all' is used in an unambiguous manner, it must be given its plain, ordinary, and natural meaning, i.e., 'every', without exception - A post's reclassification based on Pay Commission recommendations does not impliedly repeal or modify policy benefits designed for special categories like meritorious sportspersons. (Paras 8.15, 8.15.1, 8.16, 8.17, 8.20)

Facts of the case:
The applicants, meritorious sportspersons, applied for Group 'B' posts (Physical Education Teacher) advertised by DSSSB. The respondents initially issued a Corrigendum on 13.02.2020 extending age relaxation to meritorious sportspersons for Group 'B' posts. Subsequent to a High Court order, the respondents withdrew this Corrigendum via a Notice dated 17.06.2021, citing DoPT guidelines. The applicants were allowed to participate in the examination provisionally but were later rejected on grounds of age. The applicants challenged the rejection, arguing that the benefit of age relaxation under OM dated 12.11.1987 was available to them.

Findings of Court:
The Tribunal held that the action of the respondents in rejecting the candidatures of the applicants in several of the Original Applications was quashed and set aside. The respondents were directed to reassess the eligibility of those applicants in terms of the OM dated 12.11.1987. The other Original Applications were held to be premature.

Issues: The main issues were whether meritorious sportspersons are entitled to age relaxation for Group 'B' posts under the OM dated 12.11.1987, and whether the respondents' withdrawal of the Corrigendum mid-recruitment was arbitrary.

Ratio Decidendi: The court ruled that the OM dated 12.11.1987 extends age relaxation to 'all' civil posts, with the sole exception of posts filled through UPSC. The reclassification of a post from Group 'C' to Group 'B' does not take it out of the ambit of this beneficial policy. A withdrawal of the benefit mid-recruitment, after the commencement of the process, is arbitrary and illegal.

Result: Original Applications allowed in part. The rejection notices of the applicants in several O.As were quashed. The respondents were directed to reassess their eligibility with consequential benefits. The remaining O.As were disposed of as premature. No order as to costs. (Para 9.1 to 9.6)

Table of Content
1. common factual and legal background of the case (Para 1 , 2 , 3)

2026.05. SAK04 LANI1 + 7 0 : 5 2 ORDER Hon’ble Mr. Manish Garg, Member (J)

Since a common question of facts and law arises in the present O.A.s, they are being disposed of through this common order. However, for the sake of brevity, the facts are being extracted primarily from O.A. No. 1880/2022 with the consent of the learned counsel for the parties.

2. The reliefs prayed for in O.A. No. 1880/2022, reads as under:

“i. allow the present Original Application;

ii. quash the rejection Notice dated 30.06.2020 of the respondent No. 2;

iii. direct the respondents to grant benefit of age relaxation in the upper age limit to the Applicant as per OM dated 12.11.1987 and direct all consequential benefits to be given to the applicant in terms of the aforesaid prayer;

iv. pass such other order or orders as are deemed fit and proper in the facts and circumstances of the case.”

3. Highlighting the facts of the case, learned counsel for the applicant(s), drew our attention to the record of proceedings dated 05.02.2026, relevant portion of which reads as under:-

“2.1 The respondents issued Advertisement Nos. 02/20, 03/20, 04/20 & 05/20 for recruitment to various posts, including Group ‘B’ posts, wherein age ANKIANKIT T SAKLANI

2026.05. SAK04 LANI1 + 7 0 : 5 2 relaxation for meritorious sportspersons was initially not extended to Group ‘B’ posts.

2.2 Aggrieved candidates approached this Tribunal by filing OA No. 412/2020 and connected matters, contending that denial of age relaxation to meritorious sportspersons for Group ‘B’ posts was illegal and contrary to Government policy.

2.3 During the pendency of the said OAs, the respondents issued a Corrigendum dated 13.02.2020, categorically extending the benefit of age relaxation to meritorious sportspersons for all Group ‘B’ posts advertised under the aforesaid advertisements.

2.4 In view of the said Corrigendum, this Tribunal disposed of the batch of OAs as infructuous, observing:

“2. Today, it is brought to out notice by the learned counsel for the applicants that the respondents issued Corrigendum dated 13.02.2020, to the effect that the relaxation in favour of meritorious sportspersons is applicant to Group ‘B’ posts also.

In that view of the matter, the grievance of the applicants stands redressed. The OAs are accordingly closed as infructuous.”

2.5 Thereafter, the respondents filed Review Applications challenging the closure of the OAs. The Tribunal, vide order dated 02.03.2021, dismissed the Review Applications and clarified:

“3. It is not a case in which a batch of OAs was disposed of on merits or through a very detailed order. The issue was about the relaxation of age limit. During the pendency of the OAs, the respondents in the OA, i.e., the applicants in the RA issued a corrigendum dated 13.02.2020 extending the benefit of relaxation of age limit in respect of Group B posts also. Except that, it referred to the said corrigendum and closed the OAs as infructuous, the Tribunal did not make any observation on merits or any other related issues. 4. The basis for filing this batch of RAs is that the DoP&T as well as the Home Department of the Union of India are said to ANKIANKIT T SAKLANI

2026.05. SAK04 LANI1 + 7 0 : 5 2 have taken exception to the corrigendum issued by the respondents, i.e. the Delhi Administration, extending the benefit of relaxation of age limit to Group B posts also. The emphasis was that the relaxation of age limit can be only in respect of Group D posts and in certain cases, to Group C, but not to Group B posts. That is purely in the realm of the administration and the Tribunal did not issue any directions in the OA. Further, the orders in the OAs were upheld by the Hon’ble High Court of Delhi.

5. Therefore, we do not find any merit in the RAs and the same are accordingly rejected.”

2.6 Aggrieved, the respondents approached the Hon’ble High Court of Delhi by filing W.P.(C) No. 5790/2021 and connected matte

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