Delhi High Court Strikes Down Arbitrary Cut-off Dates for OBC-NCL Certificates in CAPF Exams

Court mandates certificates issued within the financial year to be valid, ensuring fairness and upholding constitutional rights.

In a landmark judgment, the Delhi High Court has declared the cut-off period for the issuance of OBC-NCL certificates in the Central Armed Police Forces (CAPF) Assistant Commandant (AC) Examination as arbitrary and violative of the Constitution. The court emphasized that the certificates should be valid if issued within the relevant financial year, thereby ensuring fairness and equality in public employment.

The judgment came in response to a series of writ petitions filed by candidates whose OBC-NCL certificates were rejected due to being issued outside the stipulated cut-off period. The petitioners argued that this arbitrary cut-off deprived them of their fundamental rights under Articles 14 and 16 of the Constitution.

The court, led by Justices C. Hari Shankar and Om Prakash Shukla, noted that the requirement for OBC-NCL certificates to be issued within a narrow window was not communicated to candidates in a timely manner. This left them with an impractical timeframe to procure the necessary documentation, effectively limiting their opportunity to benefit from the reservation policy.

The judgment highlighted that the OBC-NCL certificate merely affirms a pre-existing status and should not be treated on par with acquiring a new qualification. The court found that the cut-off dates lacked a rational nexus with the objective of reservation, which is to promote equality in public employment.

Furthermore, the court referred to the doctrine of legitimate expectation, emphasizing that candidates could reasonably expect administrative bodies to act fairly and communicate requirements in a timely manner. The decision mandates that OBC-NCL certificates issued within the financial year should be accepted, thus providing relief to the petitioners.

This ruling is expected to have significant implications for future examinations, ensuring that deserving candidates are not unjustly deprived of their rights due to procedural technicalities. The court's decision reinforces the principles of fairness and equality embedded in the Constitution, offering a renewed assurance to candidates from reserved categories.

Bottom Line:

Rule stipulating cut-off period for issuance of OBC-NCL certificates in CAPF (AC) Examination was held arbitrary and violative of Articles 14 and 16 of the Constitution. The cut-off period must correspond to the financial year, and OBC-NCL certificates issued within the relevant financial year shall be considered valid.

Statutory provision(s): Articles 14, 16 of the Constitution of India

Raghvendra Singh v. Union Public Service Commission, (Delhi)(DB) : Law Finder Doc Id # 2820306