The Jharkhand High Court dismissed various appeals referred to itself, affirming that candidates must produce caste certificates in the prescribed format and within the specified cutoff date in recruitment notifications to claim reservation benefits.
The appellants had appeared in various recruitment processes conducted by Jharkhand Public Service Commission (JPSC) and Jharkhand Staff Selection Commission (JSSC), and claimed reservation benefits on the basis of certificates produced after the cutoff date or in formats other than those prescribed. They challenged the rejection of their reservation claims and the consequent treatment as general category candidates, arguing that their certificates should have been accepted at the stage of document verification, relying on the Ram Kumar Gijroya judgment[1].
The petitioners had failed to submit the required caste certificates either in the prescribed format or within the cutoff date specified in the recruitment advertisements. The current case involves conflicting decisions by different division benches of the Jharkhand High Court in cases of candidate with similar situations. While some benches had accepted certificates produced at verification regardless of the cutoff date, others emphasized strict adherence to advertisement conditions. This led to allegations of violation of equality and reservation mandates, and prompted multiple writ petitions and appeals.
The petitioners contended that Ram Kumar Gijroya authorized acceptance of caste certificates even after the cutoff date if produced during document verification, especially because obtaining valid certificates timely is sometimes difficult. On the other hand, the State and recruitment bodies argued that strict enforcement of cutoffs is essential to maintain fairness, prevent administrative chaos, and avoid undue advantage to late submitters.
The Larger Bench comprising Chief Justice Tarlok Singh Chauhan, Justice Ananda Sen, and Justice Rajesh Shankar examined the issue in light of Supreme Court pronouncements, emphasizing administration stability, uniformity, and constitutional guarantees under Articles 14, 16, and 335. The Court found that the cutoff date is sacrosanct, and late or invalid certificates cannot be accepted without harming equitable recruitment.
The Bench further clarified that the applicability of Ram Kumar Gijroya judgment is limited, especially where clear cutoff rules and formats exist, and cannot justify relaxation beyond cutoff dates for caste certificate submissions. The doctrine of ignorantia juris non excusat applies in these cases, where candidates must adhere to advertisement conditions and seek clarifications proactively if ambiguities arise.
Additionally, the Bench also observed that certificates must be issued by designated authorities in the prescribed formats. Certificates from other authorities or formats are invalid, as set out by the Supreme Court precedents such as Mohit Kumar[2].
In result, the Larger Bench clarified that possession of a properly formatted caste certificate by the cutoff date is a mandatory eligibility criterion for reservations in government recruitments. Candidates who fail to meet this may be considered under the general category without breaching constitutional principles.
The court rejected the argument that caste certificates could be accepted post cutoff date based on Ram Kumar Gijroya, distinguishing it due to new Supreme Court rulings which mandate adherence to cutoff dates and strict documentation.
The court upheld the recruitment commissions’ authority to deny reservation benefits where candidates did not comply with requirements, preserving administrative order and equality. The case was remanded to appropriate benches to decide individual appeals based on these principles.
Cases relied on:
1. Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board & Another, (2016) 4 SCC 754
2. Karn Singh Yadav v. Government of NCT of Delhi & Others, (2024) 2 SCC 716
3. Jharkhand Staff Selection Commission v. State of Jharkhand & Others, P.A. Nos. 610 of 2017 and 618 of 2017 (Jharkhand HC)
4. Prem Chand Kumar v. State of Jharkhand & Others, P.A. No. 469 of 2015 (Jharkhand HC)
5. Staff Selection Commission v. State of Jharkhand & Others, P.A. No. 57 of 2018 (Jharkhand HC)
6. Sweta Kumari @ Sweta Kumari v. State of Jharkhand & Others, L.P.A. No. 91 of 2020 (Jharkhand HC)
7. Indra Sawhney & Others v. Union of India & Others, 1992 Supp (3) SCC 217
8. Pushpa v. Government (NCT of Delhi), 2009 SCC OnLine Del 281
9. Tej Pal Singh v. Government (NCT of Delhi), 1999 SCC OnLine Del 1092
10. Valsamma Paul v. Cochin University, (1996) 3 SCC 545
11. Divya v. Union of India & Others, (2024) 1 SCC 448
12. Charles K. Skaria v. C. Mathew, (1980) 2 SCC 752
13. Rekha Chaturvedi v. University of Rajasthan, 1993 Supp (3) SCC 168
14. Bhupinderpal Singh v. State of Punjab, (2000) 5 SCC 262
15. Ashok Kumar Sonkar v. Union of India, (2007) 4 SCC 54
16. Ashok Kumar Sharma & Others v. Chander Shekhar & Another, (1997) 4 SCC 18
17. Mohit Kumar v. State of Uttar Pradesh and Others, 2025 SCC OnLine SC 1125
18. Registrar General, Calcutta High Court v. Shrinivas Prasad Shah, (2013) 12 SCC 364
19. Sakshi Arha v. The Rajasthan High Court & Others, 2025 SCC OnLine SC 757
20. M.V. Nair v. Union of India & Others, (1993) 2 SCC 429
21. Andhra Pradesh Public Service Commission v. Baloji Badhavath, (2009) 5 SCC 1
22. Rakesh Kumar Sharma v. Govt. of NCT of Delhi & Others, 2013 SCC OnLine SC 674
Case Details:
For the Appellants: Mr. Krishna Murari, Mr. Raj Vardhan, Ms. Mitali Raj, Mr. Ritesh Pathak, Mr. Rabindra Nath, Advocates (In LPA 64 of 2020, LPA 117 of 2020)
Mr. Shresth Gautam, Mr. Yogendra Prasad, Advocates (In LPA 49 of 2020, LPA 74 of 2020, LPA 76 of 2020, LPA 87 of 2020, LPA 88 of 2020, LPA 92 of 2020, LPA 103 of 2020, LPA 104 of 2020 & LPA 105 of 2020)
Mr. Manoj Tandon, Ms. Neha Bhardwaj, Ms. Sneha Kumari, Advocates (In LPA 77 of 2020, LPA 133 of 2020)
Mr. Nitish Parth Sarthi, Ms. Chandana Kumari, Advocates (In LPA 114 of 2020)
Mr. Prem Mardi, Mr. Mukesh Kumar Mehta, Advocates (In LPA 115 of 2020)
Mr. Indrajit Sinha, Mr. Amritansh Vats, Advocates (In LPA 125 of 2020, LPA 126 of 2020, LPA 127 of 2020, LPA 128 of 2020, LPA 183 of 2020, LPA 193 of 2020)
Mr. Rohit Ranjan Sinha, Mr. Akchansh Kishore, Advocates (In LPA 266 of 2020)
For the Respondents: Mr. Rajiv Ranjan, Advocate General (State) Mr. Ashutosh Anand, A.A.G. III; Mr. Ashok Kumar Yadav, Sr. S.C. I; Mr. Manish Kumar, Sr. SC II; Mr. Rahul Saboo, GP II; Mr. Mithilesh Singh, G.A. IV; Mr. Jayant Franklin Toppo, GA V; Mr. Piyush Chitresh, AC to AG; Mr. Gaurav Raj, AC to AAG II; Mr. Rakesh Kumar Shahi, AC to SC (L&C) I; Ms. Chaitali C. Sinha, AC to AAG IA; Mr. Rohit, AC to AAG I; Ms. Divya, AC to SC III
For the JPSC & JSSC: Mr. Sunil Kumar, Sr. Advocate; Mr. Sanjay Piprawall, Ms. Rohini Prasad, Mr. Prince Kumar, Mr. Rakesh Ranjan, Mr. Jay Prakash, Advocates
[1] (2016) 4 SCC 754
[2] 2025 SCC OnLine SC 1125
