The Supreme Court has stated that caste certificates must be presented in the specific format prescribed in the recruitment advertisement, and candidates cannot claim exemption from this requirement merely based on their belonging to a particular category. A bench consisting of Justice Dipankar Dutta and Justice Manmohan denied relief to a candidate who had applied for positions advertised by the Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) using an OBC caste certificate in a format valid for central government jobs, instead of the specific format required by the advertisement. According to the advertisement, candidates who failed to present the caste certificate in the prescribed state format would be considered under the unreserved category.
Due to the failure to submit the OBC certificate in the format prescribed by the state government, the candidate, who was disqualified from the recruitment process, filed a writ petition before the Allahabad High Court. The High Court also dismissed the petition, prompting the candidate to appeal to the Supreme Court. In its judgment, the Supreme Court relied on the case Registrar General, Calcutta High Court v. Srinivas Prasad Shah (2013), in which it was stated that certificates should be issued by the competent authority in the format specified in the advertisement, or else it could adversely affect the candidate’s eligibility.
The Court emphasized, “Failure to comply with the conditions set forth in the advertisement/notification is likely to result in the rejection of the candidate’s claim for a reserved category, if they do not adhere to these conditions. Therefore, it would be appropriate for the selection body or appointing authority not to consider the candidate’s application under the community for which reservation is applicable.” The Court further stated that the recruitment authority is the best judge of the recruitment process, and generally, courts should avoid intervening once the recruitment process has commenced.
The Court also noted that candidates are expected to read and understand the recruitment notification before applying. Failure to do so means they cannot contest the selection process later, particularly when they have not followed the specific requirements outlined in the advertisement.
The Court remarked, “If a candidate does not make an effort and takes a chance based on their own interpretation of the advertisement, they cannot later challenge the selection on the grounds that the disputed terms could have been understood differently.” It was stated that candidates should not be expected to doubt the format of the certificate they are submitting. Instead, they could have contacted the relevant authority to obtain the correct certificate, rather than arguing that submitting the caste certificate was merely a technical formality, especially when they belonged to a specific caste.
The Court concluded, “With this in mind, Mohit and Kiran (the candidates in the relevant case) cannot argue that the insistence on providing the 17 certificates in the format required by UPPRPB was just a formality that could have been avoided since they had certificates issued in a different format.” In light of this, the Court dismissed the appeal and refused to grant relief to the candidate.