Summary
The Supreme Court upheld denial of EWS treatment to Civil Services Examination 2022 candidates whose prescribed income-and-asset certificates did not meet the applicable possession and upload deadlines. The required certificate formed part of eligibility, rather than being merely later proof of an independently established status. The Court upheld the examination rules and cut-off, distinguished trivial errors from material defects, and declined selective relaxation or Article 142 relief.
Issues
- Whether EWS eligibility required the prescribed certificate by the preliminary-application closing date and timely upload with DAF-I.
- Whether the examination rules and deadlines were enforceable and constitutionally valid.
- Whether later certificates, corrections, provisional interviews or treatment of minor defects entitled these candidates to relief.
Provisions considered
- Rules 13, 27(3) and 28, Civil Services Examination Rules, 2022Candidates required the prescribed certificate based on financial year 2020–21 by 22 February 2022 and had to upload it within the DAF-I deadline; the requirements were mandatory. (¶¶ 6, 7, 8, 9, 10, 11, 12, 39, 40, 41, 45, 52, 74, 77, 78, 86)
- EWS eligibility requirements and clause 5 of the 31 January memorandum, DoPT Office Memoranda dated 19 and 31 January 2019EWS benefit required the competent authority’s income-and-asset certificate in the prescribed format, read with the examination rules and their cut-offs. (¶¶ 4, 5, 39, 41, 44, 45, 74, 86)
- Article 73, Constitution of IndiaThe duly gazetted examination rules were enforceable, supplementing the service recruitment framework and traceable also to the Union’s executive power. (¶¶ 48, 49, 50, 86)
- Article 14, Constitution of IndiaThe closing date was a valid, non-arbitrary eligibility cut-off; selective relaxation could prejudice persons who refrained from applying. (¶¶ 51, 61, 86)
- Article 142, Constitution of IndiaExceptional relief was declined because proper application of the rules achieved complete justice and no case for their relaxation was established. (¶¶ 84, 85)
Held
- For CSE-2022, EWS eligibility required satisfaction of the prescribed criteria and possession by 22 February 2022 of the prescribed certificate based on financial year 2020–21. That document then had to be uploaded with DAF-I within its deadline. Later production or rectification did not automatically relate back. (¶¶ 39, 40, 41, 44, 45, 52, 86)
- Authorities allowing later proof of an already-acquired qualification were distinguishable. Here certification itself was part of the prescribed EWS eligibility. The exceptional pandemic relief in Deepak Yadav did not establish a general relaxation rule, and Divya’s factual explanation was unpersuasive. (¶¶ 42, 43, 44, 45, 54, 55, 56, 57, 58, 59, 60)
- The examination rules supplemented the statutory recruitment framework and were also traceable to Article 73. They were notified before selection and enforceable; fixing eligibility on the application closing date did not violate Article 14. (¶¶ 47, 48, 49, 50, 61, 86)
- Selective relaxation would undermine equal treatment of non-applicants and certainty of the completed selection. The Court did not decide the separate estoppel argument based on participation. (¶¶ 51, 52, 53, 61, 62)
- Provisional interviews and requests to cure deficiencies did not waive the rules. Material defects concerning the required financial year and eligibility differed from the trivial omissions accepted in other candidates’ otherwise compliant certificates. The examining body’s decisions remained subject to equality and non-arbitrariness. (¶¶ 74, 75, 76, 77, 78, 79, 80, 81, 82, 83)
- UPSC’s rejection of the petitioners’ EWS claims was justified. The circumstances did not warrant Article 142 relief. (¶¶ 81, 84, 85, 86, 87)
Result
All writ petitions dismissed without costs. The examination rules, possession and upload deadlines, and denial of the petitioners’ EWS categorisation were upheld; Article 142 relaxation refused.