Inadvertent Technical Error In Online Application Not Suppression Of Facts: Madhya Pradesh High Court Sets Aside Candidate’s Disqualification
The Court held that strict recruitment clauses relating to domicile mismatch are intended to prevent fraud and misrepresentation, and cannot be invoked to disqualify a candidate on account of a bona fide data entry error having no impact on merit.
Manoj Manav, Advocate, appeared for the petitioner, while Nidhi Bohara, Advocate, appeared for the respondents.
Background
The petitioner had applied for the post of Constable (GD) pursuant to a recruitment advertisement issued by the Staff Selection Commission. While filling the online application through a kiosk, the domicile district was incorrectly entered as “Khargone” instead of the actual domicile “Shajapur”.
However, in the same application form, the petitioner correctly mentioned his permanent and postal address as Kalapipal, District Shajapur. Despite clearing all stages of the selection process, including securing 90% marks in the written examination, his candidature was rejected at the stage of document verification due to this discrepancy.
The petitioner contended that the error was a bona fide data entry mistake attributable to the kiosk operator and had no bearing on merit or eligibility. The respondents, on the other hand, relied on the strict terms of the advertisement, which prohibited any change in domicile after the submission of the application.
Court’s Observation
The Court emphasised that a clear distinction must be drawn between an inadvertent error and deliberate misrepresentation. It distinguished an inadvertent technical error and the suppression of material facts.
The Court observed that recruitment rules are designed to prevent fraudulent claims of domicile or reservation benefits, and not to penalise genuine candidates for minor mistakes.
The Court analysed the object behind strict clauses in recruitment advertisements and held that their purpose is protective, not punitive, observing that the stringent clauses are fundamentally designed as a shield to penalise misrepresentation and prevent unscrupulous candidates from illegally usurping territorial reservations. They are not intended to be applied as a mechanical sword.
A significant factor weighed by the Court was the internal consistency of the application form. It noted that while the domicile column contained an incorrect entry, the permanent and postal address columns correctly reflected the petitioner’s actual domicile.
The Court held that if the petitioner had intended to misrepresent his domicile, he would have altered all relevant fields in the application. The presence of correct address details established that the error was mechanical and not deliberate.
The Court further found that the petitioner had not gained any competitive advantage due to the error. It noted that the petitioner had secured significantly higher marks than the cut-off and that the respondents failed to demonstrate that the incorrect domicile conferred any benefit in terms of relaxed eligibility criteria or lower cut-off. Thus, the error was held to be immaterial to the selection process.
The Court relied upon the decision in Vashist Narayan Kumarv. State of Bihar (2024), wherein the Supreme Court recognised that trivial errors should not result in cancellation of candidature after successful participation in the selection process. Applying the principle of de minimis non curat lex, the Apex Court had Court held that “candidature can only be cancelled, after careful scrutiny of the gravity of the lapse, and not for trivial omissions or errors.”
The Court found that the rejection of candidature was arbitrary and reflected a non-application of the mind. It noted that in an earlier round of litigation, the authorities had been directed to examine whether the error was merely technical and had no effect on selection. However, the respondents failed to undertake such an assessment and mechanically rejected the candidature.
Conclusion
The High Court held that the error in the petitioner’s application was a bona fide and trivial data entry mistake which had no bearing on merit or selection. It quashed the rejection of candidature and directed the respondents to accept the petitioner’s original domicile certificate and process his appointment strictly on merit, without treating the mismatch as a disqualification.
Cause Title: Rohit Gami v. Union of India Through Chairman Staff Selection Commission (Neutral Citation: 2026:MPHC-IND:8131)
