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Rajasthan High Court vs. Rajat Yadav

Not available · 2025 INSC 1503Decided 19 Dec 2025
Not available
Justice Dipankar Datta · Justice Augustine George Masih

Background

The Rajasthan High Court advertised 2,756 posts of Junior Judicial Assistant/Clerk Grade-II, to be filled via a written test (300 marks) followed by a typewriting test (100 marks), with candidates shortlisted for the typewriting stage category-wise, up to five times the number of vacancies. Because cut-off marks for several reserved categories (SC, OBC, MBC, EWS) were set higher than the General category cut-off, meritorious reserved-category candidates who scored above the General cut-off, but below their own category's higher cut-off, were excluded from the shortlist altogether, rather than being counted in the open/General list. Several affected candidates challenged this before the Rajasthan High Court, which ruled in their favour and directed that the General/Open list be prepared strictly on merit first (including any reserved-category candidates who qualify on merit), before drawing up separate reserved-category lists. The High Court's own administration appealed this ruling to the Supreme Court.

Decision Breakdown

The Supreme Court upheld the High Court's Division Bench ruling. It held that a reserved-category candidate who scores high enough to qualify on merit alone must be treated as a General/Open category candidate at the shortlisting stage itself: this is not "migration" (which the earlier case of Chattar Singh had restricted to the final merit-list stage) but simply the application of the constitutional principle that a more meritorious candidate cannot be confined to a reserved slot merely because of their caste/category. The Court distinguished Chattar Singh because there the preliminary exam marks did not count toward final merit, whereas here the written test carried substantial weight (75% of the total). Treating the open category as if reserved exclusively for General candidates, while excluding higher-scoring reserved candidates, violated Articles 14 and 16. The appeals were dismissed and the impugned High Court order upheld, though the Court added a caveat protecting reserved candidates from being unfairly deprived of a preferred post within their own quota due to this rule, and directed that already-appointed candidates not be disturbed as far as possible.

Lesson Learnt

In public recruitment with multi-stage selection, a reserved-category candidate who scores high enough to qualify purely on merit must be counted in the open/General category at every stage of shortlisting (not just the final merit list): reservation guarantees a minimum floor of representation, it does not cap a more meritorious candidate's rightful place in the open category.

Official source (sci.gov.in)View Judgment (PDF)

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