The Supreme Court has held that a candidate’s failure to submit an Other Backward Class (OBC) certificate in the format prescribed under a recruitment notification justifies their exclusion from selection under the reserved category. The Court dismissed a plea by Mohit Kumar and allowed the appeal of the Uttar Pradesh government against a High Court order favouring another candidate, Kiran Prajapati.
The judgment was delivered by a bench comprising Justice Dipankar Datta and Justice Manmohan in Civil Appeal Nos. 5233-5234 of 2025.
Background of the Case
The Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) issued a notification on February 24, 2021, for recruitment to posts including Sub-Inspector, Civil Police, and Platoon Commander for 2020-21. Both Mohit Kumar and Kiran Prajapati applied under the OBC category and appeared for the examination.
Mohit scored 313.84 marks, exceeding the OBC cut-off (305.542) but below the general category cut-off (316.11). Kiran scored 287 marks, which also qualified under the OBC category (cut-off: 285.92) but not for general. However, both submitted their OBC certificates in the format prescribed for Central Government appointments instead of the one mandated by the State Government.
As a result, they were treated as general category candidates and were not selected. Their respective representations to UPPRPB were rejected.
Mohit’s challenge to the rejection was dismissed by the High Court. However, in Kiran’s case, the High Court directed UPPRPB to accept her certificate, which led to the state’s appeal before the Supreme Court.
Submissions and Legal Issues
Counsel for the State of Uttar Pradesh argued that the recruitment was governed by the Uttar Pradesh Sub-Inspector and Inspector (Civil Police) Service (Amended) Rules, 2015, and the Uttar Pradesh Public Services (Reservation for SCs, STs, and OBCs) Act, 1994. Clause 5.4(4) of the recruitment notification explicitly warned that candidates failing to submit OBC certificates in “Format-I” would be treated as general category applicants.
It was contended that the Central Government’s OBC certificate lacks the financial and asset-based exclusions mandated by the State Government to assess non-creamy layer status. Accepting such certificates would force UPPRPB to make subjective assessments, contrary to the uniformity intended under the recruitment rules.
On the other hand, counsel for the candidates argued that the certificates were issued by competent tehsildars, that their community status was not in dispute, and that their hard-earned merits should not be overlooked due to technical formatting differences.
Supreme Court’s Observations
The Court ruled that the condition requiring submission of the certificate in a particular format was not a mere formality but a mandatory requirement. It emphasized:
“Once a process of recruitment is set in motion, all aspirants are entitled in law to equal treatment. There cannot be different yardsticks for different sets of aspirants.”
Citing its earlier decision in Registrar General, Calcutta High Court v. Shrinivas Prasad Shah (2013), the Court reiterated that the benefit of reservation must be proven through a valid certificate issued by the competent authority in accordance with the applicable rules.
The Court further stated:
“Clause 5.4(4) with which we are concerned is far from ambiguous. It is absolutely clear what UPPRPB required and what would be the consequence of non-adherence.”
The bench also clarified that prior High Court decisions in similar cases, where relief was granted, were not binding as they were not decisions on merits but dismissals at the admission stage.
Final Decision
The Court dismissed Mohit Kumar’s appeal and allowed the Uttar Pradesh government’s appeal in the case of Kiran Prajapati. It concluded:
“For the reasons aforesaid, Mohit and Kiran are not entitled to any relief.”
Citation: Mohit Kumar vs State of Uttar Pradesh & Ors, Civil Appeal No. 5233 of 2025; State of Uttar Pradesh & Anr vs Kiran Prajapati, Civil Appeal No. 5234 of 2025.
