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Punjab and Haryana High Court Dismisses Munisha's Appeal Over Expired BCA Certificate
Chandigarh, – The has dismissed an appeal filed by a candidate who sought to rely on a fresh Backward Class-A (BCA) certificate obtained after the application deadline to claim eligibility for a teaching post. A Division Bench comprising Justice Harsimran Singh Sethi and Justice Minderjeet Yadav upheld the Single Judge's order canceling Munisha's candidature for the post of Primary Teacher (PRT) in the Mewat Cadre under the BCA category.
Case Background: A Tale of Expired Validity
The dispute arose from Advertisement No. 5 of 2024 issued by the for 1,456 PRT posts. The last date for submission of applications was . As per the advertisement, BCA category candidates were required to attach a valid certificate issued in terms of the state's instructions dated . Clause 11 of the advertisement made it clear that failure to attach the requisite documents would result in outright cancellation of candidature.
Munisha applied and attached a BCA certificate issued in . She was allowed to compete provisionally. However, during scrutiny in 2025, it was discovered that the certificate had lost its validity on , as per the 2022 instructions. The instructions state that certificates involving income or creamy layer criteria are valid only till March 31 of the financial year of issue. Since the application was submitted months after this date, the certificate was deemed invalid. Consequently, Munisha was not permitted to continue in the selection process under the BCA category.
Appellant's Argument: Fresh Certificate Should Suffice
, representing Munisha, argued that by the time scrutiny took place, she had obtained a fresh valid BCA certificate. He contended that since only the fact of eligibility needed to be demonstrated, the subsequent certificate should be considered. He also pointed out that less meritorious candidates had been appointed and three BCA posts remained vacant, arguing that the appellant should be accommodated.
State's Stand: Terms of Advertisement Are
countered that the terms and conditions of the advertisement are binding. He emphasized that Clause 12.12 of the advertisement expressly stated that only documents uploaded with the application form would be considered. The later certificate could not cure the defect. He also cited the 's decision in Mohit Kumar vs. State of Uttar Pradesh to argue that the recruitment process must follow a for all candidates.
Legal Analysis: Adherence to Advertisement Conditions Is Mandatory
The Division Bench relied on the 's ruling in Mohit Kumar (2025 SCC Online SC 1125), which held that the terms of an advertisement are and must be strictly followed by all aspirants. The court also referred to a Coordinate Bench decision in vs. Pardeep Kumar (LPA-1397-2025), which, relying on Dolly Chhanda vs. Chairman, JEE (2005) 9 SCC 779, established the general rule that a candidate must possess the required eligibility on the last date fixed for application. Notably, an SLP against the Pardeep Kumar ruling had been dismissed by the on .
Key Observations
The court made several pivotal observations:
"Merely because subsequent to the last date, another certificate was issued to the appellant, the same will nother application form to be treated as an eligible candidate."
On the validity of the original certificate, the court noted:
"A bare perusal of the above reproduction shows that any certificate issued will lose its sanctity on 31st March of the year concerned."
Regarding the appellant's argument about vacant posts, the bench stated:
"On the mere aspect that the posts are lying vacant, appellant's candidature cannot be considered by ignoring the claim of the candidate, who competed in conformity with the application."
Court's Decision: Appeal Dismissed
Finding no ground for interference, the Division Bench dismissed the appeal. The court held that Munisha's application was correctly rejected as she failed to attach a valid BCA certificate within the prescribed timeframe. The decision reinforces the principle that recruitment advertisements must be adhered to strictly, and that .
Implications
This ruling serves as a clear reminder to candidates in public employment that all eligibility conditions must be satisfied as on the last date of application. The judgment underscores that the validity of reservation certificates is time-sensitive and that fresh certificates obtained later cannot an incomplete application.
