Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Jhk) 547

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 Res.-State: Mr. Rajiv Ranjan, A.G., Mr. Piyush Chitresh, A.C. to A.G.
For the Res.-JPSC Mr. Sanjoy Piprawall, Advocate

The state possesses executive discretion to fix recruitment cut-off dates. Judicial review is limited to instances of manifest arbitrariness or irrationality; candidates hold no vested right to demand specific age relaxations based on prior remedial policies or past recruitment history.

Headnote:(A) Jharkhand Combined Civil Services Examination Rules, 2021 - Rules 4(i), 6(i), and 6(ii) - Civil services - Age relaxation - Eligibility criteria - Cut-off date - Judicial review of executive policy.

(B) Service Law - Recruitment - Discretion of executive authority in fixing cut-off dates - Principle that fixation of a cut-off date is a policy decision and cannot be declared arbitrary unless it is capricious, whimsical, or wholly unreasonable - No vested right exists for candidates to claim age relaxation equivalent to the period of delay in conducting examinations or for a specific number of years based on past practice or previous notifications. (Paras 23, 28, 30, 34)

Facts of the case:
The appellants challenged the cut-off date for age calculation in a civil service recruitment advertisement, asserting that the government failed to conduct annual examinations as required by statute. They argued that the chosen cut-off date was arbitrary and inconsistent with past advertisements, which granted more extensive age relaxations. They invoked the doctrine of legitimate expectation, seeking a modification of the cut-off date to a year aligned with the previous recruitment cycle.

Findings of Court:
The court found that the statutory rules provided the executive with authority to club vacancies when examinations are not held for unforeseen reasons. It noted that the appellants had already benefited from significant age relaxations in prior cycles, amounting to approximately ten years. The court observed that there is no obligation for the state to provide additive or perpetual age relaxation, and the fixity of a cut-off date is within the domain of administrative policy.

Issues: The primary issues were whether the chosen cut-off date for age eligibility was arbitrary or discriminatory under constitutional standards, and whether the appellants were entitled to claim age relaxation based on previous government actions and the expectation of yearly examination cycles.

Ratio Decidendi: Determining a cut-off date for recruitment is an executive policy decision. Courts must exercise restraint and should not interfere unless the date is manifestly arbitrary or irrational. Legitimate expectation cannot be used to force the government to extend repetitive concessions that were granted as discretionary remedial measures in the past, nor can the absence of annual examinations, when provided for by a statutory proviso, create a vested right to specific age-based concessions. (Paras 28, 32, 34)

Result: Appeals dismissed.

Table of Content
1. procedural consolidation and identification of core legal challenges. (Para 1 , 2 , 3)
2. appellants argue for age relaxation based on previous precedents and legitimate expectations. (Para 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11)
3. state asserts proportionality of relaxation and executive discretion in policy-making. (Para 12 , 13 , 14 , 15 , 16)
4. statutory analysis of rule 4(i) and rule 6 regarding examination frequency and age criteria. (Para 17 , 18 , 19 , 20 , 21 , 22)
5. cumulative age relaxation establishes sufficiency, dismissing claims of arbitrariness. (Para 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30)
6. court distinguishes existing precedents and clarifies non-universality of relaxation demands. (Para 31 , 32 , 33)
7. executive authority has broad discretion to fix cut-off dates unless patently arbitrary. (Para 34 , 35)
8. final dismissal of appeals. (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 a judgment rendered by the Hon’ble Supreme Court in the case of Sivanandan C.T. and Others vs

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2026 Supreme(Jhk) 547

The state possesses executive discretion to fix recruitment cut-off dates. Judicial review is limited to instances of manifest arbitrariness or irrationality; candidates hold no vested right to demand specific age relaxations based on prior remedial policies or past recruitment history.

Cases Referred (1)