Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Jhk) 473

IN THE HIGH COURT OF JHARKHAND AT RANCHI
M. S. SONAK, C.J., RAJESH SHANKAR, J.
Niraj Kumar Pandey, S/o Yogeshwar Pandey – Appellant
Versus
The State of Jharkhand, through its Chief Secretary, Ranchi – Respondent
L.P.A. No. 202 of 2026 With L.P.A. No. 204 of 2026 With L.P.A. No. 146 of 2026
Decided On : 15-04-2026

Advocates Appeared:
For the Appellants :Mr. Amritansh Vats, Advocate, Mr. A.K. Sahani, Advocate
For the Respondents:Mr. Rajiv Ranjan, A.G., Mr. Piyush Chitresh, A.C. to A.G., Mr. Sanjoy Piprawall, Advocate

The fixation of cut-off dates for eligibility in competitive examinations is an executive policy matter immune to judicial interference unless palpably arbitrary. No vested right to age relaxation exists solely based on past examination delays when the executive has already provided reasonable compensatory relief.

Headnote:(A) Service Law - Recruitment Rules - Age relaxation - Cut-off date fixation - Scope of judicial review - Fixing cut-off dates is within the domain of the executive authority; courts should not interfere unless such orders are palpably arbitrary, capricious, or wholly unreasonable. (Paras 34, 35)

(B) Service Law - Doctrine of Legitimate Expectation - Applicability to executive policy - There is no vested right to claim age relaxation for a specific number of years merely because examinations were not conducted in prior years; executive policy granting reasonable relaxation is sufficient to meet judicial standards of fairness. (Paras 28, 30)

Facts of the case:
Appellants filed appeals against the dismissal of their petitions seeking additional age relaxation for participation in a competitive civil services examination. They contended that failing to hold the examination annually created a legitimate expectation for further relaxation, arguing that the cut-off date fixed by the government was arbitrary and failed to align with previous practices of granting extensions corresponding to the number of years the examination was missed.

Findings of Court:
The court determined that the government has the discretion to fix cut-off dates for recruitment. It noted that the appellants were already beneficiaries of multiple prior relaxations totaling nearly a decade. The court held that there is no requirement for mechanical, linear age relaxation corresponding to the duration of administrative delays, provided the policy is not outright discriminatory or unreasonable.

Issues: Whether the fixation of the cut-off date for age eligibility was arbitrary, and whether the failure to grant further age relaxation violated the doctrine of legitimate expectation.

Ratio Decidendi: The judiciary should not interfere with executive discretion in framing recruitment policies or fixing cut-off dates unless the action is blatantly discriminatory or lacks any rational basis. Legitimate expectation pertains to enforceable rights or promises, not to aspirations for perpetual or cumulative compensation for administrative delays, especially when prior relief has been granted.

Result: Appeals dismissed.

Table of Content
1. consolidation of appeals and overview of the legal challenge. (Para 1 , 2 , 3)
2. appellants contend that failure to conduct annual examinations warrants age relaxation based on past precedents and legitimate expectation. (Para 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11)
3. respondents argue that fixing cut-off dates is policy-driven and past relaxations preclude further claims of injustice. (Para 12 , 13 , 14 , 15 , 16)
4. analysis of rule 4(i) statutory framework regarding annual examination mandates and executive power for age relaxation. (Para 17 , 18 , 19 , 20 , 21 , 22)
5. assessment of reasonableness in executive policy when balancing repeated age relaxations against claims of arbitrariness. (Para 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30)
6. application of established judicial precedents regarding the limited scope of review over executive cut-off date fixation. (Para 31 , 32 , 33 , 34 , 35)
7. final order dismissing the appeals due to lack of merit. (Para 36)

JUDGMENT :

1. Heard learned counsel for the parties.

2. Learned counsel for the parties submits that these three appeals can be disposed of by a common order as the issues raised therein are the same.

3. The challenge in these appeals is to the judgments and orders passed by the learned Single Judge dismissing the appellants’ writ petitions seeking age relaxation of almost seven years in the context of Advertisement No. 01/2026 for the Jharkhand Combined Civil Services Examination-2025.

4. Learned counsel for the appellants submits that in terms of Rule 4(i) of the Jharkhand Combined Civil Services Examination Rules, 2021 (hereinafter referred to as ‘the Rule, 2021’), the Jharkhand Public Service Commission (JPSC) was bound to announce vacancies in accordance with the requisitions received from the concerned cadre controlling departments each year in such manner as it may deem fit to be filled by direct recruitment and shall invite applications from the eligible candidates. They submit that the proviso, under which the examinations for two or more years, would be held by clubbing the vacancies applied only in case of some unforeseen reasons. They submit that the normal rule was to hold the examination each year and a proviso was in the nature of an exception to this normal rule.

5. Learned counsel for the appellants point out that from 2017 to 2020, no examination was held. Ultimately, vide Advertisement No. 01/2021, the examinations were to be held for the years 2017, 2018, 2019 & 2020. This time, the respondents, by exercising the powers under Rule 6(i) of the Rules, 2021, granted age relaxation by fixing a cut-off date for the purpose of determining the age requirement as 01.08.2016. The resolution granting the age relaxation specifically referred to failure in holding examinations each year as being the reason for grant of relaxation.

6. Learned counsel for the appellants point out that similarly, vide Advertisement No. 01/2024, the Civil Services Examination, 2023 was announced for filling up the vacancies of the years 2021-2022. Even this time, five years age relaxation was granted by providing that the cut-off date shall be 01.08.2018. Again, this was on account of failure to hold the Civil Service Examinations each year.

7. Learned counsel for the appellants point out that the impugned Advertisement No. 01/2026 concerns the filling up of the vacancies for the years 2023 and 2024. This time, however, age relaxation of only four years has been granted by fixing the cut-off date as 01.08.2022, even in fact going-bye the past practice, this cut-off date should have been 01.08.2018.

8. Learned counsel for the appellants submit that there is arbitrariness in fixing the cut-off date as 01.08.2022 instead of 01.08.2018. They submit that in fixing this cut-off date, the past practices as evident from Advertisement Nos. 01/2021 and 01/2024 have been completely ignored. They submit that such action is unfair and defiance of the doctrine of legitimate expectations. They rely on

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2026 Supreme(Jhk) 473

Cases Referred (1)