In a significant judgment underscoring the importance of fairness over technical rigidity, the Delhi High Court ruled that the Union Public Service Commission (UPSC) cannot deny a candidate the benefit of reservation under the Other Backward Class (OBC) category merely because the OBC Non-Creamy Layer (NCL) certificate was issued before the prescribed cut-off date but still remained valid. The case revolved around a female aspirant for recruitment to the Central Armed Police Forces (CAPF), whose candidature was rejected by the UPSC on the sole ground that the uploaded OBC certificate had been issued prior to the specific window defined in the recruitment notice.
The petitioner had applied under the OBC-NCL category and held a valid caste certificate. However, the UPSC had stipulated that the certificate must be issued between April 1 and May 14 of that year, with the notification itself being issued after nearly half the stipulated period had already lapsed. The candidate uploaded an older certificate dated January 16 instead of obtaining a fresh one within the narrow window. Although she had the valid certificate as of April 30—squarely within the required timeframe—the UPSC considered her ineligible solely due to the earlier upload.
The Division Bench of Justice C. Hari Shankar and Justice Ajay Digpaul took a strong view against such inflexible administration. They held that rigid procedural formalities cannot defeat the substantive rights of individuals, especially when the purpose of the rule has been fulfilled. The Court emphasized that the candidate had in her possession a valid and applicable certificate within the stipulated period and had merely committed an inadvertent procedural lapse in uploading an earlier version.
The Court found the Commission’s action not only arbitrary but also inconsistent with the spirit of social justice that reservation laws are meant to uphold. It questioned how a candidate could be penalized for an administrative or clerical error when her eligibility under the OBC category was otherwise beyond dispute. It was further noted that the time window of only 44 days—of which more than half had expired before the notification—placed unreasonable constraints on aspirants from marginalized sections who may not always be able to secure new documents at such short notice.
By interpreting the rules in a manner that prioritizes substantive compliance over form, the High Court reaffirmed that the purpose of procedural requirements is to ensure fairness—not to act as barriers to justice. It held that the existence of a valid certificate within the required timeframe was sufficient to establish eligibility and that the denial of candidature solely on the basis of an earlier upload date was excessive.
The Court granted relief by allowing the petitioner to continue in the recruitment process and listed the matter for further proceedings. It also recalled that interim orders in similar matters had allowed candidates to proceed despite procedural lapses, suggesting a broader judicial consensus on the issue. This ruling underscores a crucial principle: that procedural norms must not be weaponized to negate genuine entitlements, particularly in the context of affirmative action and social equity.
The decision sends a strong message to administrative authorities like the UPSC, indicating that fairness, rationality, and sensitivity to candidates' practical constraints must be prioritized in interpreting procedural requirements. It reinforces the principle that the role of such bodies is not merely to enforce rigid formalities but to facilitate equitable participation in public employment. The Court thus stands as a guardian of both legal principle and human dignity in the administrative machinery of the state.
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