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IN THE HIGH COURT OF MADHYA PRADESH AT INDORE
JAI KUMAR PILLAI, J.
Yogendra Singh Gurjar - Appellant
Versus
Airport Authority Of India And Others - Respondent
Writ Petition No.4532 of 2026
Decided On : 06-03-2026
(1) Constitution of India -- Art. 226 -- territorial jurisdiction -- language employed in advertisement for recruitment does not confine territorial jurisdiction to Courts in Mumbai alone -- in absence of parties' intention to confine jurisdiction solely to Courts at Mumbai, this Court would certainly have jurisdiction to dwell upon issue in dispute. (1989) 2 SCC 163 = 1989 SCC Online SC 122 followed. [Para 14
(2) Civil Services -- domicile -- petitioner did not upload his own domicile certificate -- uploaded domicile certificate of his father -- domicile certificate issued in favour of father during candidate's minority cannot perpetually serve as adult candidate's independent proof of domicile, especially when competing for public employment where strict adherence to documentary requirements is mandated -- held -- father's domicile certificate cannot be treated as valid domicile certificate of petitioner for purpose of this recruitment -- petitioner subsequently produced domicile certificate issued in his own name well after cut-off date -- participation in recruitment process requires strict compliance with essential eligibility conditions -- requirement was not merely to be a domicile, but to possess and upload valid proof of such status prior to cut-off date -- by uploading his father's certificate instead of his own, petitioner failed to meet mandatory application requirements -- furthermore, other candidates who did not possess valid domicile certificates on cut-off date were similarly rejected -- granting indulgence to petitioner would amount to arbitrary relaxation of mandatory conditions -- would result in reverse discrimination against those candidates who strictly adhered to rules or were similarly rejected -- in absence of power under advertisement to relax condition of producing valid domicile certificate before cut-off date, respondents did not commit any mistake or illegality in rejecting candidature of petitioner -- Courts must be slow in interfering with process of recruitment where rejection flows automatically from non-compliance of mandatory conditions by candidate himself -- impugned action of rejecting candidature does not suffer from manifest arbitrariness, unreasonableness or violation of Articles 14, 16 or 21 of Constitution. [Paras 18 to 25
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ORDER :
JAI KUMAR PILLAI, J.
The present writ petition under Article 226 of the Constitution of India has been preferred by the petitioner invoking a Writ of Certiorari to quash the decision of the verification committee dated 31.01.2026, whereby the petitioner’s candidature for the post of Junior Assistant (Fire Services) under the Airports Authority of India (Western Region) was rejected. The petitioner further seeks a Writ of Mandamus directing the respondents to consider his candidature, accept his domicile certificates, and permit him to participate in the remaining stages of the selection process.
2. The facts of the case are that the respondent No.2 issued Advertisement No.DR-01022025WR dated 11.02.2025 for the direct recruitment of Non-Executives, including the post of Junior Assistant (Fire Services). The advertisement mandated that candidates must be domiciles of Maharashtra, Gujarat, Madhya Pradesh, or Goa.
3. The petitioner, born on 04.10.2000 and claiming to be a permanent resident of Madhya Pradesh since birth, applied online for the said post prior to the last date of submission. During the online application process, the Petitioner uploaded the domicile certificate of his father, Shri Laxman Singh Gurjar, dated 14.06.2016, instead of his own within the last date i.e. 24.03.2025.
4. The petitioner was issued an E-Admit Card and successfully cleared the Computer Based Test (CBT) held on 06.06.2025. Consequently, he was issued a Call Letter dated 24.12.2025 directing him to appear for document verification on 31.01.2026 at Vadodara Airport.
5. During the document verification, the petitioner produced his educational certificates, a Light Motor Vehicle Driving Licence, his father’s domicile certificate dated 14.06.2016, and his own domicile certificate dated 05.01.2026. The verification committee orally rejected the Petitioner’s candidature on the ground that he failed to produce his own domicile certificate issued prior to the cut-off date for filing the application form i.e. 24.03.2025.
6. Learned counsel for the petitioner submitted that the rejection of the Petitioner’s candidature is arbitrary, illegal, and violative of Articles 14, 16, and 21 of the Constitution. It was contended that the advertisement only required a domicile certificate in the prescribed format and did not stipulate any cut-off date for its issuance.
7. It was further argued that a domicile certificate merely evidences a pre-existing fact of permanent residence and does not create the status. The petitioner’s continuous residence in Madhya Pradesh is conclusively established by his educational records, Samagra ID, and his father’s 2016 domicile certificate. The Petitioner’s own certificate dated 05.01.2026 validates this continuous status.
8. Lastly, the petitioner contended that the oral rejection without providing a prior show-cause notice, an opportunity to be heard, or a reasoned written order amounts to a gross violation of the principles of natural justice and defeats his legitimate expectation of fair treatment after successfully clearing the CBT.
9. Per contra, learned counsel for the respondents raised a preliminary objection regarding the maintainability of the petition on the ground of territorial jurisdiction, submitting that the advertisement explicitly stipulated Mumbai as the forum for dispute resolution.
10. On merits, it was submitted that Clauses 6(i), 6(ii), 6(x), 8(e) (iii), and 8 (f) of the Advertisement mandatorily required the uploading of the candidate's scanned domicile certificate prior to the cut-off date of 24.03.2025. The petitioner failed to upload his own valid domicile certificate during the application stage, instead uploading his father's certificate, which constitutes incorrect information.
11. It was further contended that strict adherence to the eligibility conditions is mandatory in competitive recruitment. The petitioner produced his own domicile certificate dated 05.01.2026, well after the cut-off date. Providing
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