Court’s Decision
The Delhi High Court, comprising Justice Navin Chawla and Justice Madhu Jain, dismissed a writ petition filed by two candidates challenging the rejection of their candidature for the post of Security-cum-Fire Guard Grade-II at the All India Institute of Medical Sciences (AIIMS), New Delhi, on the ground that their OBC Non-Creamy Layer (NCL) certificates were issued beyond the prescribed period.
The Court affirmed the Central Administrative Tribunal’s order dated 29 May 2025, which had refused to interfere with AIIMS’s decision. The Bench held that the advertisement’s stipulation regarding validity of certificates between 1 April 2022 and 31 March 2023 was mandatory, and any deviation from it would amount to unjustified relaxation.
Observing that candidates cannot feign ignorance of explicit recruitment terms, the Court quoted the Supreme Court in Sakshi Arha v. Rajasthan High Court (2025 SCC OnLine SC 757):
“Ignorance of the law is no excuse. The advertisement required production of a valid certificate as per prescribed rules and instructions.”
Accordingly, the writ petition was dismissed, and the rejection of candidature was held valid and lawful.
Facts
AIIMS had issued a recruitment notification dated 14 November 2022 for multiple posts, including 35 posts of Security-cum-Fire Guard Grade-II (13 for UR, 3 for EWS, 4 for SC, 3 for ST, and 12 for OBC). The petitioners applied under the OBC-NCL category, appeared in the written examination on 27 March 2023, and secured ranks 32 and 33 respectively in the OBC merit list.
However, as per the notification, OBC candidates were required to produce valid NCL certificates issued between 1 April 2022 and 31 March 2023, strictly following the DoPT’s format prescribed in Office Memoranda dated 30 May 2014 and 31 March 2016.
The petitioners submitted certificates issued after the stipulated cut-off date—one on 5 December 2023 and another on 19 July 2023—even though both claimed they were valid for the financial year 2022-23. Their candidature was consequently rejected by AIIMS on 13 January 2024.
Aggrieved, they approached the Central Administrative Tribunal (CAT) in OA No. 248/2024, but the Tribunal dismissed their claim, holding that the delay in issuance of certificates was not attributable to AIIMS. The petitioners then filed the present writ petition under Article 226 of the Constitution before the Delhi High Court.
Issues
- Whether AIIMS was justified in rejecting OBC-NCL certificates issued after the prescribed financial year (1 April 2022 to 31 March 2023).
- Whether such rejection violated the petitioners’ right to be considered under the OBC category, despite their undisputed social status.
- Whether the High Court could relax or overlook a mandatory recruitment condition pertaining to document validity.
Petitioners’ Arguments
The petitioners argued that they belonged to the OBC-NCL category by birth, and therefore, their candidature could not be rejected merely on a technical ground relating to the date of issuance of certificates. Their OBC status was undisputed and permanent, evidenced by earlier certificates issued in 2016 and 2017.
They contended that both certificates, though issued after the cut-off date, explicitly stated validity for the financial year 2022-23, and hence met the spirit of the recruitment condition.
Reliance was placed on the Supreme Court judgment in Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board (2016 SCC OnLine SC 184), where candidates were allowed to produce category certificates after the cut-off date, as the delay was due to administrative reasons. The petitioners also cited Union of India v. Abdul Rasheed (Kerala High Court, 2016), upheld by the Supreme Court, to argue that rejection of a candidate merely for late issuance of caste certificate is arbitrary.
Respondents’ Arguments
AIIMS, though not represented during hearing, relied on its recruitment advertisement, which clearly stated that only certificates issued between 1 April 2022 and 31 March 2023 would be valid. The Tribunal’s findings, supported by Supreme Court precedent, were deemed conclusive: since the petitioners’ certificates fell outside the stipulated window, their candidature was invalid.
The respondents’ stance was fortified by Sakshi Arha v. Rajasthan High Court and Mohit Kumar v. State of Uttar Pradesh (2025 SCC OnLine SC 1125), where the Supreme Court emphasized that candidates must strictly adhere to advertisement terms, and no relaxation can be claimed as a matter of right.
Analysis of the Law
The Court relied heavily on the Supreme Court’s interpretation of eligibility and certificate validity in Sakshi Arha and Mohit Kumar, underscoring that recruitment advertisements are legally binding and must be strictly complied with.
In Sakshi Arha, the Supreme Court categorically held that:
“A certificate of claim is valid for one year from the date of issuance and extendable up to three years if supported by an affidavit. Candidates must possess valid certificates as on the last date of submission of applications.”
Similarly, in Mohit Kumar, the Apex Court reiterated that eligibility must exist as of the cut-off date, and the appointing authority is the best judge of its requirements. Once recruitment rules are public, no candidate can later seek relaxation, and non-compliance triggers automatic disqualification.
Applying these principles, the Delhi High Court concluded that:
- AIIMS had clearly prescribed the validity period for OBC-NCL certificates.
- The petitioners did not possess certificates issued within that window.
- There was no evidence of delay attributable to AIIMS or any authority.
Thus, the claim of arbitrariness was untenable.
Precedent Analysis
- Sakshi Arha v. Rajasthan High Court (2025 SCC OnLine SC 757) — Clarified that ignorance of recruitment terms is no excuse; certificate validity is binding and non-negotiable.
- Mohit Kumar v. State of Uttar Pradesh (2025 SCC OnLine SC 1125) — Held that certificate requirements in recruitment notifications are mandatory and must be strictly followed.
- Ram Kumar Gijroya v. DSSSB (2016 SCC OnLine SC 184) — Distinguished; applicable only when delay in issuance was due to the authorities themselves.
- Union of India v. Abdul Rasheed (Kerala HC, 2016) — Upheld principle of fairness but found inapplicable since AIIMS had issued an explicit time-bound condition.
The Court harmonized these rulings to assert that while equity can supplement law, it cannot override clear recruitment terms.
Court’s Reasoning
The Bench observed that the advertisement unambiguously limited validity of OBC-NCL certificates to the financial year 2022–23. The petitioners’ documents, issued in 2017 and mid-2023, fell outside this range.
The Court found that the petitioners had adequate opportunity to obtain valid certificates during the stipulated period and that failure to do so was solely attributable to them, not to administrative delay.
It reiterated the Supreme Court’s dictum that:
“Once a process of recruitment is set in motion, all aspirants are entitled to equal treatment. There cannot be different yardsticks for different aspirants.”
Therefore, accepting certificates issued after the cut-off would amount to unfair relaxation, breaching Article 14 and Article 16 of the Constitution. The Court emphasized that recruiting bodies are the best judges of their procedural requirements and that judicial interference is limited to cases of manifest arbitrariness or discrimination, neither of which existed here.
Conclusion
The Delhi High Court upheld the Central Administrative Tribunal’s decision and dismissed the petition, holding that:
“The advertisement unambiguously stipulated that only OBC-NCL certificates issued between 01.04.2022 and 31.03.2023 shall be considered valid. The petitioners’ failure to comply with this renders them ineligible.”
The Court found no illegality, arbitrariness, or procedural lapse on AIIMS’s part and observed that the Tribunal’s order was consistent with Supreme Court jurisprudence.
The writ petition and all pending applications were dismissed, with no order as to costs.
Implications
- Reinforces strict adherence to recruitment advertisement conditions.
- Clarifies that OBC status alone does not confer eligibility; timely certification is essential.
- Emphasizes uniform application of cut-off dates to preserve equality in public employment.
- Limits judicial discretion to cases involving administrative delay or discrimination.
- Serves as precedent for recruitment authorities and tribunals in enforcing certificate validity rules.