OBC Certificate Not in State-Prescribed Format May Lead To Rejection In Recruitment

A bench of Justices Dipankar Datta and Manmohan heard appeals arising from the Uttar Pradesh Police Recruitment and Promotion Board’s (UPPRPB) 2020-21 Sub-Inspector recruitment process, addressing whether candidates who produced OBC/NCL caste certificates in the Central Government format (and not the State-prescribed Format‑I) were entitled to be considered against OBC vacancies. The appeals arose from conflicting High Court orders: one dismissing a writ petition filed by Mohit Kumar and another allowing a writ petition filed by Kiran Prajapati.

The Supreme Court rejected the challenge by Mohit and allowed the appeal by the State in the connected matter, holding that the recruiting authority was entitled to insist on the certificate in the format specified in the recruitment notification. The Court emphasised that compliance with the terms of the advertisement was mandatory and that the selecting body could treat candidates who failed to submit the prescribed format as unreserved. The Court, in its reasoning, observed: “What follows from the above decision is that irrespective of whether an aspirant for public employment belongs to a particular community like SC/ST/OBC, the status claimed by him for being accorded the benefit of reservation is per se not decisive. Such status has to be certified by the competent authority upon following due process and identification that the aspirant is what he claims to be. ... Non-compliance with the terms of the advertisement/notification is bound to trigger adverse consequences of rejection of the aspirant’s claimed status by the selecting body/appointing authority, should he choose not to adhere to the same. Having regard thereto, the selecting body/appointing authority would be justified in not entertaining the application of an aspirant as a member of the community for whom reservations are permissible.” The Court further noted that “clause 5.4(4) ... is far from ambiguous” and that candidates who doubted the applicability of a term ought to have sought clarification or obtained the requisite certificate from the competent authority.

Background

The dispute arose from a UPPRPB notification dated 24 February 2021 for direct recruitment to Sub-Inspector (Civil Police), Platoon Commander, PAC and Fire Officer for 2020-21. Mohit Kumar applied and scored 313.84 marks but his name featured on the non-selected list because UPPRPB treated him as unreserved, holding that he had submitted an OBC certificate in the Central Government format rather than Format‑I prescribed by the State. UPPRPB explained that Format‑I required a declaration that the parents’ gross annual income for three continuous years did not exceed Rs. 8 lakh and that the candidate did not possess wealth above the Wealth Tax exemption limit, criteria reflected in a State Government order of 17 December 2014. The cut‑offs were higher for general category candidates.

Mohit first obtained a direction from the High Court to get his representation considered; the Superintendent, UPPRPB rejected the representation and the High Court later dismissed Mohit’s writ petition on 22 March 2023. Kiran Prajapati, who had scored 287 marks and similarly submitted a Central-format OBC certificate, obtained relief from a single judge of the Allahabad High Court directing UPPRPB to accept her certificate; that order was upheld by a Division Bench, prompting the State’s appeal to the Supreme Court.

Before the Supreme Court, the State contended that clause 5.4(4) of the advertisement explicitly disallowed Central-format certificates and relied on statutory rules and state policy for creamy-layer identification; it invoked precedents including a Full Bench decision in Gaurav Sharma and Registrar General, Calcutta High Court v. Shrinivas Prasad Shah. Counsel for the candidates urged leniency and reliance on precedents permitting remedial measures where mere technicalities caused denial of reservation benefits. The Supreme Court held that the recruitment conditions were clear, candidates had an obligation to comply or seek clarification, and that non-compliance justified rejection of their claim for reservation. The lead appeal was dismissed and the connected appeal was allowed.

Case Details: Case No.: CIVIL APPEAL NOS. 5233-5234 OF 2025 (2025 INSC 704) Case Title: Mohit Kumar v. State of Uttar Pradesh & Ors.; State of Uttar Pradesh & Anr. v. Kiran Prajapati Appearances: For the Petitioner(s): Mr. Rahul Kaushik, Senior Counsel (for Mohit Kumar); Mr. Kumar Gaurav (for Kiran Prajapati) For the Respondent(s): Ms. Ruchira Goel, Advocate (for State of Uttar Pradesh and UPPRPB)