Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(P&H) 19551

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Ashwani Kumar Mishra, Kuldeep Tiwari, JJ
Haryana Public Service Commission – Appellant
Versus
Pardeep Kumar – Respondent
LPA-1397-2025|LPA-1827-2025|LPA-1828-2025|LPA-1829-2025|LPA-1830-2025|LPA-1831-2025|LPA-1832-2025|LPA-1833-2025|LPA-1845-2025|LPA-1846-2025|LPA-1847-2025|LPA-1848-2025|LPA-1850-2025|LPA-1853-2025|LPA-1855-2025|LPA-1857-2025|LPA-1858-2025|LPA-1859-2025|LPA-1860-2025|LPA-1861-2025|LPA-1862-2025|LPA-1840-2025|LPA-1841-2025|LPA-1852-2025|LPA-1854-2025|LPA-1856-2025|LPA-1864-2025|LPA-1865-2025|LPA-1867-2025|LPA-1869-2025|LPA-1877-2025|LPA-1883-2025|LPA-1396-2025

Advocates:
For the Appellants/Petitioners: Lokesh Sinhal, Kanwal Goyal, Sheena Dahiya, Komal Klana
For the Respondents: D.S. Patwalia, Sehar Navjeet Singh, Amit Jhanji, Sarthak Gupta, Arjun Singh, Abhishek Premi, Kamal Kumar Mor, Ajay Putter, Akshay Jindal, Bhavya Vats, Harkirat Singh, Vikram Singh, Balraj Singh Rathee, Vijay Deep Rathee, Indu Bala, Anju Bansal, Dixit Garg, Parveen Kumar Rohilla, Ankur Kaushik, Naman Jain, Aneesh Sharma, Mazlish Khan

The cut-off date specified in a recruitment advertisement for possessing essential qualifications and category certificates is mandatory and sacrosanct. Failure to possess or submit these documents by the stipulated deadline justifies the rejection of candidature to ensure fairness, meritocracy, and administrative finality in public appointments.

Headnote:(A) Constitution of India - Article 14 and 16 - Reservation in public employment - Requirement to possess eligibility qualification and supporting certificates by the closing date - Instructions in advertisement mandating possession of caste and income-based certificates on or before the closing date are sacrosanct - Non-compliance with terms regarding submission of prescribed documents by the stipulated deadline leads to rejection of candidature - (Paras 31, 35, 38, 53)

(B) Recruitment Law - Eligibility vs. Proof of Eligibility - Distinction between acquiring eligibility and furnishing proof thereof - While some relaxation in presenting proof may be permitted in exceptional cases where factual eligibility is undisputed and no fault lies with the candidate, this does not permit candidates to submit documents after the cut-off date to satisfy eligibility criteria crystallizing on that date - Appointment process must maintain finality to prevent administrative chaos. (Paras 40, 45, 51, 72)

Facts of the case:
The selection process for a public appointment post was initiated via an advertisement prescribing a specific closing date for the submission of online applications. The advertisement required candidates to possess essential qualifications, caste certificates, and income-based certificates for the current financial year on or before the closing date. Several candidates failed to submit the required category-based certificates in the prescribed format by the cut-off date. The candidates subsequently challenged the rejection of their applications after qualifying in the written examination phase, arguing that the cut-off date for submission of documents was not sacrosanct and they possessed the underlying eligibility status by the closing date.

Findings of Court:
The court held that the terms of the advertisement, which explicitly stated that eligibility and supporting documentation must be possessed by the closing date, are binding. The court observed that for reservation benefit, the criteria, such as income thresholds for specific categories, must be met by a date certain for the commission to assess status accurately. Extending the date for submission of documents would disrupt the merit-based selection process and create uncertainty.

Issues: Whether the cut-off date for the submission of caste and category certificates is mandatory, and whether the correction of clerical errors in application forms or late submission of documents is permissible after the expiry of the advertised closing date.

Ratio Decidendi: The court ruled that the closing date stipulated in an advertisement for the possession of essential qualifications and supporting documents is sacrosanct. Eligibility for reserved categories crystallizes upon possession of valid, officially issued certificates by the cut-off date; thereafter, the submission of such proofs cannot be relaxed as it fundamentally alters the conditions of the recruitment process and violates the requirement for equal treatment of all aspirants.

Result: Appeals allowed; the judgment of the single bench is set aside and writ petitions dismissed.

Table of Content
1. advertisement terms and cut-off dates for eligibility are mandatory. (Para 1 , 2 , 3 , 4 , 6 , 7 , 8 , 9)
2. failure to submit required category certificates before the cut-off date invalidates candidature. (Para 10 , 11 , 12 , 13)
3. arguments favoring relaxation of procedural requirements and reliance on legitimate expectations. (Para 14 , 15 , 16 , 17 , 18 , 19 , 20 , 21)
4. competing contentions on the sanctity of cut-off dates versus substantive eligibility. (Para 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30)
5. precedent dictates that eligibility and proof must exist by the specified cut-off date. (Para 31 , 32 , 33 , 34 , 35 , 36 , 37 , 38 , 39 , 40 , 41 , 42 , 43 , 44 , 45 , 46 , 47 , 48 , 49 , 50 , 51 , 52 , 53 , 54 , 55 , 56 , 57 , 58 , 59 , 60 , 61 , 62 , 63 , 64 , 65)
6. incorrect category declaration due to candidate negligence cannot be rectified post-submission. (Para 66 , 67 , 68 , 69 , 70 , 71 , 72)
7. final order setting aside the lower court decision and dismissing the writ petitions. (Para 73 , 74)

******

ASHWANI KUMAR MISHRA, J.

1. These bunch of Appeals arises out of a composite judgment dated 15.02.2025, passed by the learned Single Bench in a bunch of Writ Petitions wherein a direction is issued to the Haryana Public Service Commission (hereinafter referred to as “the Commission”) to accord benefit of reservation to the writ petitioners on the basis of their respective certificates of different categories i.e. BC(A), BC(B) and EWS submitted after the last date fixed for filing such certificates, along with their applications, pursuant to the advertisement. Slight variance in facts in the case of the petitioner, namely, ‘Neha Dhiman’ was noticed and dealt with, separately by the learned Single Judge, Ultimately, the orders of the Commission holding the petitioners ineligible, were set aside and all the petitions were allowed.

2. The records reveal that the Commission issued an advertisement No.16/2024 on 21.06.2024, inviting applications for appointment to 805 posts of Ayurvedic Medical Officers (Group B) in Health & Ayush Department, Haryana. The advertisement contained various details required from the candidates as also the prescription of qualification and specified the date for commencement of submission of online applications as “22.06.2024” and closing date specified was “12.07.2024” at 5 P.M. The instructions accompanying the advertisement specified that candidates were to register online on the Commission's website in order to submit their application forms. After registration, they were to create a login ID and complete the registration process using the login credentials. For the purposes of authentication of candidate, Parivar Pehchan Patra (PPP), Adhar Card and Virtual ID (VID) were admissible. After registration, the candidate could apply as per their qualifications.

3. The duly filled application-form could be submitted only after payment of requisite fee. The candidates, after making payment of requisite fee, were required to take a print-out of their application form and upload the same, after duly checking and signing its contents. The process of submission of applications was to be completed only after uploading of duly signed uploaded application form by the candidates. The last date for submission of the application was “12.07.2024”. Relevant portion of the said advertisement is reproduced as under:-

Item(s)	Timeline
Date of Publication	21.06.2024
Opening date for submission of online applications (Opening Date)	22.06.2024.
Closing date for submission of online applications (Closing Date)	12.07.2024

1. XXXXXX

2. XXXXXXX

3. LATE DATE FOR RECEIPT OF APPLICATIONS:

The online Applications can be submitted up to the Closing Date till 5:00 P.M. The eligible candidates shall be issued an e-Admit Card well before the commencement of the written test, if any. The e-Admit Card will be made available on the website http://hpsc.gov.in/en-us/ for downloading by the candidates.

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2025 Supreme(Online)(P&H) 19551

Cases Referred (5)