Insistence Of Caste Certificate In A Requisite Format Not A Mere Formality: Supreme Court Upholds Non-Selection Of Candidate By UPPRPB

The Court remarked that a candidate cannot take shelter under the plea that insistence on the part of UPPRPB of certificates issued in the requisite format is a mere formality which could have been dispensed with since they had certificates issued in the other format. The Court dismissed the Appeal filed by the candidate against his non-selection due to the format of the certificate.

A Bench of Justice Dipankar Datta and Justice Manmohan remarked, “It has not been shown that obtaining a second certificate in the format required by the State Government was barred by any law. Having regard thereto, both Mohit and Kiran cannot take shelter under the plea that insistence on the part of UPPRPB of certificates issued in the requisite format is a mere formality which could have been dispensed with since they had certificates issued in the other format…Finally, the reason why UPPRPB has insisted for the certificate in the requisite format as explained by Ms. Goel [recorded in paragraph 9 (vi) to (viii) above] commends our acceptance.”

Senior Advocate Rahul Kaushik represented the Appellant, while AOR Ruchira Goel appeared for the Respondents.

Brief Facts

The Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) issued a notification on for direct recruitment to the posts of Sub-Inspector, Civil Police, and Platoon Commander, PAC, and Fire Officer. The Appellant applied for these positions but was not selected because he submitted the OBC certificate in the format prescribed for Central Government appointments, rather than the specific format required by the State Government.

Court’s Reasoning

The Supreme Court remarked, “Once a process of recruitment is set in motion, all aspirants are entitled in law to equal treatment. There cannot be different yardsticks for different sets of aspirants. Non-compliance with the terms of the advertisement/notification is bound to trigger adverse consequences of rejection of the aspirant’s claimed status by the selecting body/appointing authority, should he choose not to adhere to the same. Having regard thereto, the selecting body/appointing authority would be justified in not entertaining the application of an aspirant as a member of the community for whom reservations are permissible.”

“Clause 5.4(4) of the recruitment notification has been noticed above. It clearly warns what the consequence would be should an aspirant fail to submit the requisite certificate in Format–I. Admittedly, the certificates submitted by Mohit and Kiran do not align with Format-I,” the Bench noted.

The Court, therefore, stated, “Viewed thus, we need not even carry the discussion forward to ascertain whether Mohit and Kiran have been unfairly treated.”

The Bench further remarked that “recruiting authority is the best judge of what its requirements are and it is such understanding of the recruiting authority that would matter most in cases brought up before the courts; hence, after commencement of the process wherein aspirants have participated without raising any demur as to what a particular terms means, even if any of the terms be ambiguous, the courts should lean in favour of the recruiting authority.”

Consequently, the Court ordered, “For the reasons aforesaid, Mohit and Kiran are not entitled to any relief...Consequently, the lead appeal is dismissed while the connected appeal is allowed.”

Accordingly, the Supreme Court dismissed the Appeal.

Cause Title: Mohit Kumar v. State Of Uttar Pradesh & Ors. (Neutral Citation: 2025 INSC 704)

Appearance:

Appellant: Senior Advocate Rahul Kaushik; AOR Tom Joseph and Ruchira Goel; Advocate Kumar Gaurav, Kristen Sleeth, Veera Mahuli and Sharanya Singh

Respondents: AOR Ruchira Goel and Tom Joseph; Advocates Veera Mahuli, Sharanya Singh, Kumar Gaurav, Arya Krishnan and Prashant Bhardwaj

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