Supreme Court Bench of Justices Abhay S. Oka, Ahsanuddin Amanullah, and Augustine George Masih Upholds Cut-Off Date for Valid Category Certificates in Rajasthan Judicial Service Exam

Introduction

In a major ruling dated April 8, 2025, a three-judge bench of the Supreme Court of India dismissed a collection of complaints submitted by candidates refused access to the Rajasistan Judicial Service Examination, 2021. These candidates were disqualified for failing to provide valid OBC-NCL, MBC-NCL, or EWS certificates by the designated cut-off date even though they had qualified the preliminary and main tests. Clarifying the dynamic character of non-creamy layer (NCL) reservations and the administrative rules supporting time-bound validation of such certificates, the Supreme Court maintained the decision of the Rajasthan High Court that the requirement to produce a valid certificate before the last date of application submission was lawful.

Background and Important Information

With an advertisement dated July 22, 2021, the Rajasistan High Court requested applications for the Civil Judge Cadre vacancies under the Rajasistan Judicial Service Rules, 2010. August 31, 2021 was the latest date applications may be sent in. The advertisement did not specify, nevertheless, any precise date by which category certificates (OBC-NCL, MBC-NCL, or EWS) to be issued. Following the preliminary and main tests, a notice dated August 4, 2022, was published declaring that the valid category certificates had to have been awarded on or before August 31, 2021.

Several candidates who passed both exam levels questioned this requirement. They claimed that the first advertisement did not impose such a condition and had sent certifications dated far later, typically in 2022. The Rajasistan High Court rejected their writ petitions, therefore triggering contemporary appeals before the Supreme Court.

Legal Requests Involved

The dispute revolved on the legitimacy of the State Government’s circulars controlling the issuing and validity of OBC-NCL and MBC-NCL certificates and on the interpretation of the Rajasistan Judicial Service Rules, 2010. The Court also consulted pertinent clauses of constitutional law pertaining to affirmative action, equality in public employment, and the dynamic character of OBC and EWS categories.

The guidelines and circulars the responders mentioned made clear that non-creamy layer certifications are good for one year from the date of issuing. Should a person remain eligible in later years, the previous certificate can be used for up to three years if an affidavit is accompanying it. Circulars released by the Department of Social Justice and Empowerment of Rajasistan on September 9, 2015, and August 8, 2019 backed these guidelines.

The main question was whether the subsequent condition added by the Subsequent Notice could retroactively compromise the rights of applicants who were otherwise successful in the choosing process.

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Points of contention of the appellants

The appellants contended that the advertisement itself said nothing regarding the day category certifications were issued. They said it was arbitrary and unfair to add a new criterion following the start of the testing procedure. They argued—especially given they already belonged to the lawful reserved category—that they should not be dismissed for procedural difficulties based on past rulings like *Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board*.

The appellants further said their category status had not altered and they had presented documentation from competent authorities. They underlined that procedural justice demanded the High Court to accept their documentation and that no fraud or dishonesty was engaged.

Arguments of the Respondents

State officials and the Rajasthan High Court said that a candidate not being part of the creamy layer determines the benefit of OBC and MBC reservation. Since NCL status is determined yearly, the certificate must show the current income and status as of the application deadline. They underlined however that certificates under government circulars are valid only for one year, extendable to three years with an affidavit.

The respondents further contended that the Supreme Court had repeatedly decided that the last day of application submission becomes the cut-off date for establishing eligibility in the absence of a designated date in the advertisement or rules. Their decisions, which support the idea that eligibility must be determined as of the closing date for applications, including *Ashok Kumar Sonkar v. Union of India*, *Rekha Chaturvedi v. University of Rajasistan*, and *Divya v. Union of India*.

Analysis of the Supreme Court

Agreeing with the respondents, the Supreme Court maintained the ruling that August 31, 2021 was the pertinent cut-off for certificate validity. This is the last day for application filing. Unlike Scheduled Castes and Scheduled Tribes whose status is set by birth, the nature of OBC-NCL and MBC-NCL status is dynamic and depends on the annual income of the family, the Court noted.

The advertisement was quiet on the date, the Court underlined, but candidates had to provide proper documentation “as per rules,” which included the relevant government circulars. Therefore, the Subsequent Notice only explained the legal position depending on current laws rather than adding a new obligation.

Furthermore noted by the Court were none of the appellants’ certificates dated before August 31, 2021 or their mandatory affidavit submission under the extension policy. The provided certifications were granted in 2022 or much before without the required affidavit for continuous validity. Under such conditions, the Court decided that the High Court’s denial of their claims was not erroneous.

differentiating Previous Opinions

The appellants mostly drew on the *Ram Kumar Gijroya* decision. The appellant there had applied for the pertinent certificate before the cut-off date but had subsequently got it later owing to administrative delay, the Supreme Court noted in separating that case. On the other hand, in the current instance, none of the appellants claimed any delay by authorities or sought for revised certificates in time. The Court so decided that the *Ram Kumar Gijroya* precedent had no relevance.

Summary and Last Verdict

The Supreme Court rejected all the challenges and maintained the High Court’s ruling that candidates have to have valid category certificates, produced by the relevant body, on or before the last date of application submission. The Court decided that the Subsequent Notice’s demand was not arbitrary but rather in line with statutory norms and government circulars. Without any such phrase in the advertisement or regulations, there is no relaxation allowed.