Chaya and Ors. Etc. v. The State of Maharashtra and Anr. Etc.
Background
The appellants, reserved-category candidates, took the Teachers Aptitude and Intelligence Test (TAIT) 2022 in Maharashtra for teacher recruitment and scored higher marks than the last-selected general-category candidate. However, they were excluded from the open/general category merit list solely because they had earlier availed a 5% marks relaxation to qualify in the separate, prerequisite Teacher Eligibility Test (TET). The Bombay High Court upheld their exclusion, relying on a Supreme Court precedent (Pradeep Kumar) to hold that candidates who availed relaxation cannot migrate to the general category. The candidates appealed to the Supreme Court.
Decision Breakdown
The Supreme Court allowed the appeals and quashed the High Court's judgment, directing that appellants who scored higher than the last selected general-category candidate be included in the general-category merit list. It held that the TET relaxation only enabled reserved-category candidates to become eligible to sit for the actual selection exam (TAIT). It was not itself an eligibility condition for appointment, and no relaxation was given in TAIT itself, where all candidates were evaluated on equal footing. The Court distinguished Pradeep Kumar, clarifying that ruling applies only where a candidate fails to meet an essential eligibility condition altogether, not where, as here, the relaxation merely created a level playing field to access the main exam. Since the recruitment rules contained no express prohibition on migration, and relaxation in a qualifying-stage criterion affects eligibility, not merit, more meritorious reserved-category candidates could not be barred from the open category.
Lesson Learnt
A relaxation given to help a candidate qualify for a preliminary/eligibility-stage test does not automatically disqualify that candidate from being considered on pure merit in the open category for the main selection exam, unless the recruitment rules expressly say so: eligibility relaxations and merit-based selection are legally distinct concepts.