Rajasthan Public Service Commission, Ajmer v. Lavanshu Sankhla & Ors.
Background
The Rajasthan Public Service Commission (RPSC) advertised 181 posts of Assistant Prosecution Officer, requiring applicants to possess a law degree. The respondents, recent law graduates, applied online despite not yet having completed their final law examinations at the time of application, later acquiring the degree afterward. RPSC issued press notes clarifying that only candidates who held the qualification by the last date of application were eligible, and warned that ineligible applicants should withdraw or face disqualification/legal action. The respondents were nonetheless denied admit cards; they went to the Rajasthan High Court, and both the Single Judge and the Division Bench ruled in their favour, directing RPSC to let them sit the exam. RPSC appealed to the Supreme Court.
Decision Breakdown
The Supreme Court disagreed with the High Court and held that eligibility, including educational qualification, must be assessed as of the date of application submission, not any later date such as before the interview. It noted that the governing service rules had earlier contained a proviso allowing candidates in their final year to apply and later prove the qualification, but that proviso had been deliberately deleted in 2002, showing a clear legislative intent to exclude such candidates going forward. The Court rejected the High Court's approach of favouring an interpretation beneficial to candidates where the advertisement's language was actually clear and unambiguous, and held that allowing qualifications to be acquired at any later stage would create administrative uncertainty. It therefore set aside the High Court's judgment and allowed RPSC's appeals.
Lesson Learnt
For public recruitment, eligibility conditions such as educational qualifications are ordinarily assessed as of the last date for submitting the application, not any later milestone: job applicants should ensure they already hold the required qualification before applying unless the recruitment rules expressly permit a later cut-off.