Rajasthan High Court Upholds Recruitment Process: ME Category Candidates Availing CET Relaxation Can Be Considered in Vertical Categories for Main Exam

Jaipur , Rajasthan – The High Court of Rajasthan, Jaipur Bench, in a significant judgment, has dismissed a batch of writ petitions challenging the recruitment process for Junior Accountants and Tehsil Revenue Accountants. The court, presided over by Justice Sameer Jain , upheld the legality of the impugned result dated December 17, 2024, affirming that candidates from the Ministerial Employees (ME) category who availed relaxed cut-offs in the Common Eligibility Test (CET) could subsequently be considered under other reserved categories ( SC , ST, OBC, etc.) for the Main Examination without it amounting to impermissible "double reservation."

The judgment was pronounced on May 5, 2025, in the lead case of Mohit Soni & Ors. Vs. State Of Rajasthan & Ors. (SBCWP No. 278/2025) and other connected writ petitions.

Case Background

The core controversy revolved around the recruitment process initiated by an advertisement dated June 20, 2023, for 5190 posts of Junior Accountant and 198 posts of Tehsil Revenue Accountant. A key feature was the 12.5% horizontal reservation for candidates from the Ministerial Employees (ME) category.

Candidates first appeared for the Common Eligibility Test – Graduation Level Examination, 2022 (CET). The cut-off for the ME category in CET was set at 31.8792, substantially lower than other categories. The petitioners' grievance arose when candidates who qualified CET under this relaxed ME category cut-off were subsequently considered for selection in their respective vertical reservation categories (General, SC , ST, OBC, MBC) in the Main Examination, even if they did not meet the higher ME category cut-off for the Main Exam (519.12).

The petitioners argued that this amounted to an impermissible "benefit of double reservation" and violated Rule 6 of the Rajasthan Common Eligibility Test Rules, 2022 (CET Rules, 2022).

Arguments Presented

Petitioners' Contentions: * Candidates availing relaxed CET standards under the ME category must remain in that category for the Main Examination. * Allowing these candidates to "migrate" to other vertical categories ( SC , ST, OBC) after benefiting from the ME relaxation was illegal. * This conferred an unlawful dual benefit, prejudicing other candidates and violating Articles 14 and 16 of the Constitution. * They cited judgments like Jitendra Kumar Singh & Ors. vs. State of U.P. & Ors. and Gaurav Pradhan & Ors. vs. State of Rajasthan & Ors.

Respondents' Contentions (State and Rajasthan Staff Selection Board): * The CET is a screening/eligibility test, distinct from the Main Examination which is governed by the Rajasthan Subordinate Accounts Service Rules, 1963. * Rule 6(iii) of the 1963 Rules mandates 12.5% reservation for ME category candidates. * The process adhered to the Department of Personnel (DoP) circular dated June 24, 2008, which outlines the methodology for horizontal and vertical reservations. * Relaxation in CET was to ensure 15 times the number of candidates for the Main Exam, as per CET Rules. * There was no illegal "migration" but an application of established reservation principles where horizontal reservation is adjusted against vertical categories. * Cited Saurav Yadav v. State of U.P. and Vikas Shankla v. Vikas Kumar Agarwal .

Court's Analysis and Findings

Justice Sameer Jain , after a thorough examination of the rules, constitutional provisions, and precedents, found no merit in the petitioners' arguments.

Key Findings: * Mandatory ME Reservation: The Court highlighted Rule 6(iii) of the Rajasthan Subordinate Accountant Services Rules, 1963, which unequivocally provides for a 12.5% reservation for Ministerial Staff, deeming it a "mandatory reservation." > "As per Rule 6 (iii) of the Rules of 1963, it is unequivocally provided that “12.5% of the total number of posts of Junior Accountant shall be filled in by way of direct recruitment from amongst the Ministerial Staff..."

Adherence to DoP Circular: The Court noted that the selection process followed the DoP Circular dated June 24, 2008, which details the implementation of horizontal and vertical reservations. Clause 20.3 of this circular mandates that horizontal reservations are adjusted against vertical categories post-selection.

Nature of CET vs. Main Exam: The Court differentiated between the CET (a preliminary qualifying exam) and the Main Examination (a substantive selection test). Rule 6 of the CET Rules, 2022, allows relaxation in qualifying marks to ensure adequate representation (15 times the vacancies) for the Main Examination. > "Therefore, since fifteen times candidates were not available for the posts of Junior Accountant and Tehsil Revenue Accountant, the candidates were ‘made eligible’ to fill the application forms for the competitive examination."

No Impermissible Migration or Double Reservation: The Court held that considering ME category candidates (who availed CET relaxation) under their respective vertical categories ( SC /ST/OBC) if they qualified on merit did not amount to illegal migration or double reservation. > "It is noted that neither the advertisement nor the governing rules explicitly prohibit ME category candidates from being considered under SC /ST/OBC category, if they otherwise qualify on merit. In this context, such consideration does not amount to migration or double reservation but rather reflects the integration of horizontal reservation within vertical categories, as recognized by constitutional jurisprudence."

Reliance on Supreme Court Precedents: The Court extensively relied on Saurav Yadav & Ors. vs. State of Uttar Pradesh & Ors. and Vikas Shankla vs. Vikas Kumar Agarwal , which clarified the interplay of horizontal and vertical reservations and upheld the adjustment of horizontally reserved candidates against vertical categories if they qualify on merit. > Quoting Saurav Yadav : "reservations, both vertical and horizontal, are method of ensuring representation in public services. These are not to be seen as rigid 'slots'..." > Quoting Vikas Shankla : "...Migration from reserved category to general category shall be admissible to those reserved category candidates who secured more marks obtained by the last unreserved category candidates who are selected, subject to the condition that such reserved category candidates did not avail any other special concession. It is clarified that concession of passing marks in TET would not be treated as concession falling in the aforesaid category.”

Petitioners' Standing: The Court also observed that the petitioners had not challenged the application form format or the DoP circular, and none of them had secured marks higher than the cut-off in their respective vertical categories.

Final Decision and Implications

The High Court concluded that the recruitment agency acted within the bounds of statutory provisions, administrative guidelines, and constitutional mandates. The relaxation of standards for ME category candidates under CET Rules and the subsequent integration of horizontal reservations with vertical categories were found to be legally sound.

> "In view of the above analysis and the well-settled legal principles governing horizontal and vertical reservations, this Court finds no merit in the contentions raised by the petitioners... Accordingly, the present batch of petitions being bereft of any merits stand dismissed. The result dated 17.12.2024 is not liable to be quashed or interfered with."

This judgment reinforces the established principles of reservation policy, particularly the distinction between preliminary eligibility tests and main selection exams, and the methodology for applying horizontal reservations in conjunction with vertical reservations in public employment.