Madhya Pradesh Public Service Commission v. Manish Bakawale & Ors.
Background
The respondent applied for Madhya Pradesh's 2016 State Service Examination and listed his order of preference for various posts, including Deputy Superintendent of Police as his second choice. He scored enough marks to be placed in the main selection list for that post, but was later found medically ineligible because his height (162 cm) fell short of the required minimum (168 cm). He then sought to be considered instead for his next listed preference, the post of Chief Municipal Officer, pointing out that another candidate with the same marks as him had been appointed to that post. The High Court's Single Judge and Division Bench both ruled in his favour and directed the Commission to consider him for CMO or another preferred post.
Decision Breakdown
The Supreme Court held that once a candidate is selected in the "main list" for a higher-preference post based on his declared eligibility, the relevant recruitment rule bars him from being considered for any other preferred post, even if he is later found ineligible for the first post. The respondent had expressly declared in his application that he met the physical eligibility criteria for the post he preferred, and he could not turn around afterward and claim a lower-preference post once the selection process for all posts had already been finalized together. The Court set aside the High Court's orders and restored the selection process as originally conducted by the Commission.
Lesson Learnt
When a recruitment process asks candidates to rank post preferences and declare their own eligibility, a false or mistaken declaration of eligibility for a higher-preference post cannot later be used to claim a lower-preference post: candidates bear responsibility for the accuracy of their own eligibility declarations.