A valid Heavy Motor Vehicle driving license must exist as on the cut-off date. Renewal after expiry, even if applied for before the cut-off date, does not validate the license retrospectively for eligibility purposes.

Headnote:(A) Service Law - Recruitment - Essential Qualification - Validity of Driving License - Motor Vehicles Act, 1988 - Sections 14 and 15 - Possession of valid Heavy Motor Vehicle driving license as on closing date of application is mandatory and cannot be relaxed - Cut-off date for eligibility is sacrosanct - Renewal of license after the cut-off date does not relate back to validate the license on the crucial date - The amendments brought by the Motor Vehicles (Amendment) Act, 2019 have omitted the earlier 30-day grace period, and a license now ceases to be valid from the day after its expiry.

(B) Administrative Law - Principles of Eligibility - A candidate must fulfill all eligibility criteria as on the cut-off date - Discrimination by allowing similarly situated but ineligible candidates does not create a right in favor of others - Doctrine of negative equality under Article 14 applies.

(C) Interpretation of Statutes - Amendment - Deliberate omission by the legislature must be given full effect - The statutory change in Sections 14 and 15 of the Motor Vehicles Act cannot be treated as cosmetic, and courts must not import a beneficial interpretation to override the plain language of the statute.

Facts of the case:
The applicants applied for the post of Constable (Driver) Male in Delhi Police pursuant to a recruitment notification dated 08.07.2022. The closing date for receipt of applications was 29.07.2022. The notification required candidates to possess a valid driving license for Heavy Motor Vehicles as on that date. The applicants' driving licenses had expired before 29.07.2022, and although they applied for renewal, the renewed licenses were issued after the cut-off date. The applicants challenged the denial of permission to appear in the Trade Test.

Findings of Court:
Applying the settled law in Telangana State Level Police Recruitment Board vs. Penjarla Vijay Kumar & Ors. (2025), the court held that post the 2019 amendment to the Motor Vehicles Act, a license does not continue to be effective after its expiry. Renewal operates from the date of renewal and does not validate the license retrospectively for the period of expiry. Consequently, on the crucial date of 29.07.2022, the applicants did not possess a valid HMV license and were ineligible. The court also rejected arguments based on discrimination and administrative convenience, holding that the eligibility conditions are sacrosanct.

Issues: Whether the applicants can be said to have possessed a valid HMV/Transport Licence on the relevant date of eligibility, i.e., the closing date for receipt of applications.

Ratio Decidendi: The court ruled that under the amended Motor Vehicles Act, a driving license ceases to be valid from the day after its expiry, and renewal does not relate back to the date of expiry. Therefore, if the license was expired on the cut-off date, the candidate is ineligible, regardless of subsequent renewal.

Result: Original Applications dismissed as devoid of merits.

Central Administrative Tribunal Principal Bench, New Delhi O.A. No. 3435/2023 with O.A. No. 3455/2023, O.A. No. 3436/2023, O.A.

No. 3481/2023, O.A. No. 3452/2023 with C.P. No. 5/2024, O.A. No. 3449/2023 with C.P. No. 6/2024, O.A. No. 3434/2023 with C.P. No.

897/2023, O.A. No. 3439/2023, O.A. No. 3444/2023 with C.P. No.

892/2023, O.A. No. 3438/2023, O.A. No. 3440/2023, O.A. No. 3441/2023, O.A. No. 3442/2023, O.A. No. 3443/2023, O.A. No. 3445/2023, O.A. No.

3448/2023, O.A. No. 3450/2023, O.A. No. 3451/2023, O.A. No. 3454/2023, O.A. No. 3458/2023, O.A. No. 3459/2023 and O.A. No. 3460/2023, th This the 28 Day of April, 2026 Hon’ble Mr. Manish Garg, Member (J)

Hon’ble Dr. Anand S Khati, Member (A)

O.A. No. 3435/2023 BHUPENDER SINGH ROLL NO. 2201004551, S/O LILU SINGH, R/O E BLOCK GALI NO. 10, HOUSE NO. 560 NEHRU VIHAR, DAYAPUR, DELHI- 110094.

...APPLICANT (By Advocate : Mr. Nimish Chib)

VERSUS

1. UNION OF INDIA, THROUGH SECRETARY, DEPARTMENT OF PERSONNEL & TRAINING, MINISTRY OF PERSONNEL, PUBLIC GRIEVANCE & PENSION, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI – 110001.

2. STAFF SELECTION COMMISSION, THROUGH IT’S CHAIRMAN (HEAD QUARTERS), BLOCK NO.12, C.G.O. COMPLEX, LODHI ROAD, NEW DELHI-110003.

3. COMMISSIONER OF POLICE, DELHI POLICE HEADQUARTERS, NEW BUILDING, BEHIND PARLIAMENT STREET POLICE STATION, NEW DELHI-110001.

...RESPONDENTS By Advocate : Mr. Gyanendra Singh, Mr. AmitYadav)

O.A. No. 3455/2023, PRADEEP KUMAR, ROLL NO.2405004542, S/O PHOOLARAM, R/O VPO TANEE THE MALSISAR, JHUNJHUNU, RAJASTHAN-331027.

...APPLICANT (By Advocate : Mr. Nimish Chib)

VERSUS

1. UNION OF INDIA, THROUGH SECRETARY, DEPARTMENT OF PERSONNEL & TRAINING, MINISTRY OF PERSONNEL, PUBLIC GRIEVANCE & PENSION, GOVERNMENT OF INDIA, NORTH BLOCK, NEW DELHI – 110001.

2. STAFF SELECTION COMMISSION, THROUGH IT’S CHAIRMAN (HEAD QUARTERS), BLOCK NO.12, C.G.O. COMPLEX, LODHI ROAD, NEW DELHI-110003.

3. COMMISSIONER OF POLICE, DELHI POLICE HEADQUARTERS, NEW BUILDING, BEHIND PARLIAMENT STREET POLICE STATION, NEW DELHI-110001.

...RESPONDENTS By Advocate : Mr. S N Verma, Mr. Hanu Bhaskar)

O.A. No. 3436/2023, SATVEER DEVANDA ROLL NO. 2405013170, S/O HAZARI LAL, R/O VPO HANUTPURA, JAIPUR, RAJASTHAN- 303601.

... APPLICANT By Advocate : Mr. Nimish Chib)

VERSUS

1. UNION OF INDIA, THROUGH SECRETARY, DEPARTMENT OF PERSONNEL & TRAINING, MINISTRY OF PERSONNEL, PUBLIC GRIEVANCE & PENSION, GOVERNMENT OF INDIA, NORTHBLOCK, NEW DELHI- 110001. 2. STAFF SELECTION COMMISSION, THROUGH IT'S CHAIRMAN (HEAD QUARTERS), BLOCK NO.l2, C.G.O. COMPLEX, LODHI ROAD, NEW DELHI-110003.

3. COMMISSIONER OF POLICE, DELHI POLICE HEADQUARTERS, NEW BUILDING, BEHIND PARLIAMENT STREET POLICE STATION, NEW DELHI-110001 ...RESPONDENTS By Advocate : Mr. Pradeep Kumar Sharma)

O.A. No. 3481/2023, Sachin Kumar, Age- 28 Years, S/o Late Sh.Bawa Singh Rio Village-Kalphari, Post- Gopipura, Tehsil-Mundawar, District-Alwar, Rajasthan-301407.

...Applicant By Advocate : Mr. Sachin Chauhan)

Versus

1. Union of India Through its Secretary, Govt. of India, Ministry of Personnel Public grievances & Pension, Department of Personnel & Training, North Block, New Delhi-110001.

2. Staff Selection Commission, Through the Chairman, S.S.C, Block No-12, CGO Complex, Lodhi Road, New Delhi -3.

3. The Commissioner of Police, Delhi Police, Police Headquarter, Jai Singh Road New Delhi.

...Respondents By Advocate : Mr. Amit Anand , Mr. S N Verma)

O.A. No. 3452/2023 with C.P. No. 5/2024, SHIVAM KUMAR, ROLL NO. 2201003210, S/O DEVENDER SHARMA, R/O VILL DABRA MAINCHA GREATER NOIDA, GAUTAM BUDH NAGAR, UTTAR PRADESH- 201310 ... APPLICANT By Advocate : Mr. Nimish Chib)

VERSUS

3. COMMISSIONER OF POLICE, DELHI POLICE HEADQUARTERS, NEW BUILDING, BEHIND PARLIAMENT STREET POLICE STATION, NE

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2026 Supreme(Online)(CAT) 5827

CENTRAL ADMINISTRATIVE TRIBUNAL9323/2023O.A./3435/2023

A valid Heavy Motor Vehicle driving license must exist as on the cut-off date. Renewal after expiry, even if applied for before the cut-off date, does not validate the license retrospectively for eligibility purposes.

CENTRAL ADMINISTRATIVE TRIBUNAL
9323/2023
O.A./3435/2023