Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(MP) 4345

IN THE HIGH COURT OF MADHYA PRADESH AT INDORE

NEUTRAL CITATION NO. 2026:MPHC-IND:8131

W.P. No. 19419/2020

ROHIT GAMI Versus UNION OF INDIA THROUGH THE CHAIRMAN, STAFF SELECTION COMMISSION AND OTHERS

Appearance:
Shri Manoj Manav -Advocate for petitioner.
Ms.Nidhi Bohara –Advocate for the respondents.

BEFORE HON'BLE SHRI JUSTICE JAI KUMAR PILLAI

Reserved on : 17/03/2026
Post on : 25/03/2026

Advocates:
For the Appellants/Petitioners: Manoj Manav
For the Respondents: Nidhi Bohara

A trivial, inadvertent clerical error in an application form, which does not confer any unfair competitive advantage and is contradicted by other internally consistent information in the same form, cannot be a valid ground to reject the candidature of a meritorious candidate.

Headnote:(A) Constitution of India - Article 226 - Recruitment process - Rejection of candidature due to domicile mismatch - Whether clerical error in online application form warrants cancellation of candidature - Held, internal consistency in application form (correct permanent address provided) proves error was bona fide - Mis-entry in drop-down list of domicile held to be a trivial error not affecting eligibility or competition - Applying the principle of 'de minimis non curat lex', cancellation unsustainable - Petition allowed.

Facts of the case:
The petitioner applied for the post of Constable (GD). Due to a technical error at a kiosk, the domicile district was entered incorrectly in the online form, although the correct residential address was provided elsewhere in the same form. Despite clearing all stages of the examination with high merit, the petitioner's candidature was rejected. The petitioner challenged this before the Court.

Findings of Court:
The Court observed that the petitioner gained no unfair advantage by the error, as his merit score was well above the cut-off. The internal consistency of the form confirmed the error was an inadvertent typo and not a fraudulent attempt to claim reservations. The order of rejection was found to be mechanical and arbitrary.

Issues: Whether an inadvertent domicile entry error in an application form should lead to the disqualification of a meritorious candidate and whether the respondents ignored the principle of internal consistency.

Ratio Decidendi: An inadvertent, trivial clerical error in an application form that does not impact the selection process or provide an unfair advantage should be treated as a technicality. Cancellation of candidature in such cases, especially when the form is internally consistent, is arbitrary and contrary to law.

Result: Petition allowed; impugned rejection order quashed.

ORDER

1. By way of the present Writ Petition filed under Article 226 of the Constitution of India, the petitioner has mounted a challenge to the impugned order dated 16.11.2020 passed by Respondent No. 3. Through the said order, the candidature of the petitioner for the post of Constable (GD) in Central Armed Police Forces (CAPFs), NIA, SSF and Rifleman (GD) in Assam Rifles Examination, 2018, has been rejected on the sole ground of a mismatch between the domicile district mentioned in his online application form and the original domicile certificate produced during the Detailed Medical Examination (DME) and document verification stage. The petitioner essentially seeks a writ of certiorari for quashing the impugned order dated 16.11.2020, and a consequential writ of mandamus directing the respondents to accept his original, valid domicile certificate of District Shajapur instead of Khargone (West Nimar), thereby processing his appointment strictly on merits.

FACTS OF THE CASE

2. The factual matrix, as delineated in the petition and drawn from the record, reveals that the Staff Selection Commission (SSC) issued an advertisement on 21.07.2018, inviting online applications for the post of Constable (GD) across various Central Armed Police Forces.

3. The petitioner, an eligible aspirant, submitted his application through the MP ONLINE portal on 15.09.2018. It is the pleaded case of the petitioner that while filling out the online form, the computer operator at the kiosk inadvertently selected the district of domicile as 'Khargone (West Nimar)' in column no. 17 from the drop-down menu, instead of his actual domicile district which is '(Kalapipal) Shajapur'.

4. Crucially, within the very same online application form, under column nos. 24 and 25 which pertain to the permanent address and postal address respectively the petitioner correctly provided his detailed address as Kalapipal, District Shajapur.

5. The petitioner asserts that this data entry error occurred due to a bona fide mistake by the kiosk operator, further compounded by a severely slow-running server. This technical sluggishness was a systemic issue that the respondents themselves had formally acknowledged via notices dated 14.08.2018 and 12.09.2018, wherein candidates were advised to utilize off-peak hours for form submission.

6. Notwithstanding the typographical error in column 17, the petitioner successfully participated in the written examination held on 18.02.2019, securing an exemplary score of 90% out of 100 marks against a cut-off of 73.8%. Following this, he was called for the Physical Standard Test (PST) and Physical Efficiency Test (PET) on 20.08.2019, which he cleared successfully, paving the way for his Detailed Medical Examination (DME) and document verification on 29.01.2020.

7. During the document verification on 29.01.2020, the petitioner submitted all original documents, including his marksheet, caste certificate, and the original domicile certificate of Tehsil Kalapipal, District Shajapur. The respondents, however, refused to accept the domicile certificate citing the discrepancy with column no. 17 of the online form. Despite the petitioner submitting an affidavit dated 06.08.2019 explaining the inadvertent error, an initial rejection order was passed on 31.01.2020. Aggrieved, the petitioner filed Writ Petition No. 3221/2020 before this Court. On 25.02.2020, with the consent of the respondents' counsel, this Court disposed of the petition directing the respondents to take an appropriate decision, specifically observing that "if the said mistake otherwise has no effect on the selection then it needs to be considered as technical error." Despite a detailed representation and the subsequent filing of Contempt Petition No. 1107/2020, the respondents passed the impugned order dated 16.11.2020, mechanically rejecting his candidature.

CONTENTIONS OF THE PETITIONER

8. The primary contention advanced on behalf of the petitioner is based on the "Internal Consiste

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2026 Supreme(Online)(MP) 4345

A trivial, inadvertent clerical error in an application form, which does not confer any unfair competitive advantage and is contradicted by other internally consistent information in the same form, cannot be a valid ground to reject the candidature of a meritorious candidate.

Cases Referred (1)