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Legal Case Shots

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Legal Case Shots is a searchable database of Supreme Court of India judgments, each broken down into the case type, the court's key holding, and a practical lesson learnt, with the full judgment available as a PDF for citation or deeper reading.

Service & Administrative LawSupreme Court of India

Mohit Kumar v. The State of Uttar Pradesh

Civil Appeal · 2025 INSC 704Decided 15 May 2025
C.A. No.-005233-005233 - 2025 (with connected Civil Appeal No. 5234 of 2025, State of U.P. v. Kiran Prajapati)
Justice Dipankar Datta · Justice Manmohan

Background

Mohit Kumar and Kiran Prajapati were candidates in a 2021 UP Police Recruitment and Promotion Board (UPPRPB) drive for Sub-Inspector/Platoon Commander posts, and both were denied selection benefits because the caste (OBC) certificates they submitted were not in the specific format UPPRPB required. Mohit's writ petition against his non-selection was rejected by the High Court while Kiran succeeded before the High Court in a separate writ petition on similar facts, producing conflicting outcomes for the two candidates from the same recruitment process, which the State appealed.

Decision Breakdown

The Supreme Court held that UPPRPB's requirement for OBC certificates to be issued in a specific prescribed format (clause 5.4(4) of the recruitment notification) was clear and unambiguous, and candidates had no reasonable excuse for not obtaining certificates in that format, especially since nothing prevented them from approaching the tehsildar for a correctly formatted certificate. The Court declined to treat the format requirement as a mere technicality that could be excused, and held that neither candidate was entitled to relief. It dismissed Mohit's appeal (upholding his non-selection) and allowed the State's connected appeal against Kiran (setting aside the relief she had earlier obtained), restoring consistency for both candidates from the same recruitment process.

Lesson Learnt

Where a recruiting authority prescribes a specific document format as an eligibility condition and communicates it clearly, courts will not excuse non-compliance as a mere formality: candidates must ensure their supporting documents strictly match the required format, and cannot rely on other coordinate High Court decisions that were never tested on merits (i.e., SLPs dismissed at the admission stage) as binding precedent.

Mohit Kumar v. The State of Uttar Pradesh – Legal Case Shots | LegalAware