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Supreme Court Emphasizes Strict Adherence to Prescribed Format for Caste Certificates in Reservation Claims

 

Supreme Court Emphasizes Strict Adherence to Prescribed Format for Caste Certificates in Reservation Claims

In a landmark judgment dated May 17, 2025, the Supreme Court of India underscored the critical importance of submitting caste certificates in the exact format prescribed by recruitment notifications when claiming reservation benefits. The bench, comprising Justice Dipankar Datta and Justice Manmohan, held that failure to comply with this requirement would result in the candidate being considered under the unreserved category, thereby forfeiting any reservation advantages.

The case in question involved a candidate who applied for positions advertised by the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB). The recruitment notification explicitly stated that candidates seeking reservation under the Other Backward Classes (OBC) category must submit caste certificates in a format prescribed by the State Government. Contrary to this requirement, the candidate submitted an OBC certificate issued in the format valid for central government jobs, not adhering to the specific state-prescribed format.

Upon review, the UPPRPB treated the candidate as belonging to the unreserved category due to non-compliance with the stipulated certificate format. Aggrieved by this decision, the candidate filed a writ petition before the Allahabad High Court, seeking relief and recognition of his OBC status for the purpose of reservation. The High Court, however, dismissed the petition, upholding the recruitment board's decision.

Undeterred, the candidate appealed to the Supreme Court, challenging the High Court's ruling. The apex court, after meticulous examination, affirmed the High Court's decision. Justice Datta, authoring the judgment, emphasized that recruitment authorities are best positioned to determine the modalities of the recruitment process. He stated that non-compliance with the explicit terms of a recruitment notification, particularly concerning the format of required documents, justifies the rejection of a candidate's claim to reservation benefits.

The Court referenced the precedent set in the case of Registrar General, Calcutta High Court v. Shrinivas Prasad Shah, (2013) 12 SCC 364, reinforcing the principle that adherence to prescribed formats and procedures is paramount in recruitment processes. The judgment highlighted that allowing deviations from specified requirements could lead to administrative chaos and undermine the integrity of the reservation system.

Furthermore, the Court observed that it is incumbent upon candidates to thoroughly read and understand the recruitment notifications before applying. Ignorance or oversight regarding the stipulated requirements cannot be grounds for post-facto challenges to the recruitment process. The Court asserted that judicial interference in recruitment processes should be minimal, especially when the procedures are transparent and uniformly applied.

This judgment serves as a crucial reminder of the necessity for candidates to meticulously adhere to all specified requirements in recruitment notifications, particularly when seeking reservation benefits. It underscores the judiciary's commitment to upholding procedural integrity and ensuring that the principles of fairness and equality are maintained in public employment processes.

In conclusion, the Supreme Court's decision reinforces the sanctity of prescribed procedures in recruitment processes and the imperative for candidates to comply with all specified requirements. It affirms that deviations from stipulated norms, especially concerning critical documents like caste certificates, cannot be condoned, thereby preserving the efficacy and fairness of the reservation system in India.

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