Kumari Laxmi Saroj & Ors. vs State of U.P. & Ors.
Background
Four women who had trained as Auxiliary Nurses/Midwives in Madhya Pradesh applied for Health Worker (Female) posts in Uttar Pradesh, which required registration with the U.P. Nurses and Midwife Council. Nearly all of them had applied for U.P. registration before the job advertisement was even published, but the U.P. Council was slow to actually issue it, so they could not produce the certificate by the time their documents were verified. Their candidature was rejected solely for lacking the U.P. registration at that stage, and the Allahabad High Court upheld the rejection, distinguishing an earlier Supreme Court ruling on similar facts as one decided only under special Article 142 powers.
Decision Breakdown
The Supreme Court held the High Court had misread its own earlier precedent (Narender Singh v. State of Haryana), which laid down a general principle, not limited to Article 142, that a candidate cannot be penalized for a delay caused entirely by the processing authority when the candidate has done everything within their control on time. Since the delay here was solely attributable to the U.P. Council's processing time and not any lapse by the appellants, the rejection was unsustainable. The Court quashed the High Court's judgment and directed the authorities to appoint the appellants within six weeks, provided they otherwise meet the merit and eligibility criteria, with all consequential benefits from their date of actual appointment.
Lesson Learnt
A job applicant cannot be denied a position for failing to produce a document by a deadline if the delay was caused entirely by the issuing authority's own processing time and not by any fault of the applicant, who had applied well within time.