EWS Reservation Strictly Contingent On Valid Financial-Year Certificate By Cut-Off Date: Supreme Court Upholds Rejection Of Candidature
|The Bench noted that defects in certificates affecting prescribed format go to the root of eligibility and then reservation benefits cannot be claimed.
The Supreme Court has reiterated that eligibility for reservation under the Economically Weaker Sections (EWS) category is strictly contingent upon possession of a valid income and asset certificate pertaining to the prescribed financial year as on the cut-off date, holding that defects in such certificates go to the root of eligibility and are not curable post facto. Dismissing the appeals, the Court upheld the Allahabad High Court’s judgment and denied relief to the appellants.
Furthermore, the Court held that where an advertisement mandates submission of certificates in a prescribed format and for a specific financial year, non-compliance renders the candidature invalid. It rejected the contention that errors attributable to issuing authorities should not prejudice candidates, noting that such defects cannot override express eligibility conditions.
Justice Manoj Misra and Justice Prasanna B. Varale while citing UPSC v. Gaurav Singh & Ors. (2024) 2 SCC 605, noted, “…this Court held that when certificate is sought in respect of a particular financial year, certificate of a different financial year goes to the root of the eligibility of a candidate. In that light, even the certificate of Sunita Kumari was invalid for claiming the benefit of reservation. In such circumstances, we do not find any good reason to interfere with the order passed by the High Court… As, admittedly, the appellants did not possess the necessary certificate in the prescribed form by the cut-off date, no relief can be accorded to the appellants.”.
Parul Shukla, AOR appeared for the appellant and Talha Abdul Rahman, AOR appeared for the respondent.
The matter pertained to recruitment to 9,212 posts of Health Worker (Female) in Uttar Pradesh, with 10% reserved for EWS candidates. The advertisement required submission of an EWS certificate issued on or before the last date of application and conforming to the prescribed format, indicating income for the financial year prior to the year of application.
The appellants applied under the EWS category but submitted certificates either issued before the close of the relevant financial year or pertaining to incorrect financial years.
After clearing the written examination, their candidature was rejected at the stage of final selection, thereafter, they approached the High Court, where a Single Judge directed issuance of fresh certificates and reconsideration of candidature, citing confusion in the terminology used in the advertisement and government orders. However, the Division Bench reversed this relief, holding the certificates invalid.
Now the core issue was whether such defective certificates could sustain a claim for EWS reservation. The Court held that both the governing Office Memorandum and the advertisement unequivocally required that the certificate relate to the financial year preceding the application year and be valid as on the cut-off date. Certificates issued prior to the closure of the relevant financial year or pertaining to a different year were inherently defective and incapable of conferring eligibility.
The Bench, rejecting the argument that candidates should not suffer for errors of the issuing authority, noted that most certificates had been obtained even before the advertisement was issued, and candidates had sufficient opportunity to obtain compliant certificates.
“Besides, in Divya v. Union of India and Others, this Court has already held that for claiming reservation under EWS category, Income and Asset Certificate of the specified financial year in the prescribed form must be in possession of the candidate on or before the cut-off date. As, admittedly, the appellants did not possess the necessary certificate in the prescribed form by the cut-off date, no relief can be accorded to the appellants”, the Bench reiterated.
“Before parting, we would like to observe that in matters of public recruitment, where large number of candidates participate, application forms are submitted online along with the scanned eligibility documents, certificates, etc. Such applications are processed through computer applications/ software and therefore, any error in the application is bound to result in rejection of the candidature. Challenge to such a rejection must not ordinarily be entertained as it could stall expeditious completion of the recruitment process thereby frustrating thousands and lacs of aspirants”, the Bench further noted.
Cause Title: Poonam Dwivedi & Ors. v. State Of U.P. & Ors. [Neutral Citation: 2026 INSC 351]
Appearances:
Appellants: Parul Shukla, AOR, Alok Mishra, Shubhangi Pandey, Gladson Rodrigues, Saday Mondol, Keesha Kumar, Vanya Gupta, AOR, Tarun Kumar Sobti, Advocates.
Respondents: Talha Abdul Rahman, AOR, Sudhanshu Tewari, Faizan Ahmed, Shuktiz Sinha, Sarvesh Singh Baghel, AOR, Shivranjani Ralawata, Pooja Singh, Dr. Vinod Kumar Tewari, AOR, Pramod Tiwari, Vivek Tiwari, Priyanka Dubey, Manindra Dubey, Saumya Mishra, Jitesh Sharma, Ramnesh Verma, Advocates.