Airport Authority of India & Ors. v. Sham Krishna B. & Ors.
Background
Several reserved-category candidates who scored high enough to qualify purely on merit were placed in the unreserved list rather than their reserved category, leaving some reserved vacancies unfilled. An unreserved candidate who narrowly missed selection challenged the process; two lower courts ordered his appointment.
Decision Breakdown
The Supreme Court held that when a reserved-category candidate qualifies purely on merit without using any relaxation, they must be counted as unreserved from the outset: a reservation roster is only an administrative tracking tool, not a device to override merit-based outcomes.
Lesson Learnt
A meritorious reserved-category candidate filling an "open" seat does not free up that seat for another candidate: the roster tracks representation, it doesn't re-rank genuine merit selections.