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Rakshit Shivam Prakash vs Union of India

Not available · 2024 INSC 569Decided 2 Aug 2024
Not available
Justice Pamidighantam Sri Narasimha · Justice Pankaj Mithal

Background

The petitioner cleared the UPSC Civil Services Examination 2014 through the Prelims, Mains, and Interview stages, but was declared "temporarily unfit" at his medical examination due to a BMI slightly above the prescribed limit. He was entitled to a re-medical test but mistakenly believed the process was already over after the final result was published without his name, so he did not attend it. Later, a reserve list was published on which he ranked 93rd, with less-meritorious candidates below him being given appointments; his subsequent attempts before the Central Administrative Tribunal and courts failed, largely because his case was linked to a similarly-placed candidate whose claim had already been rejected, until that candidate later won relief from the Supreme Court in a separate case.

Decision Breakdown

The Supreme Court noted the petitioner's situation closely mirrored that of the other candidate (K. Rajashekhara Reddy), who had also missed his re-medical test but was ultimately granted relief and appointment by the Court using its special "complete justice" power under Article 142 of the Constitution. Rejecting the petitioner's primary request for direct appointment (since nearly a decade had passed since 2015), the Court instead granted a limited, exceptional remedy: directing the authorities to give him a fresh re-medical examination within four weeks, but making clear that even if he passes, he cannot claim seniority or appointment in the original 2014 batch, and his service would begin only from the date of actual appointment. The Court expressly stated this order should not be treated as a precedent for future cases.

Lesson Learnt

Even when a person misses a procedural opportunity through their own misunderstanding, courts can grant a second chance in truly exceptional circumstances using their special constitutional powers to do complete justice, but such relief is fact-specific, comes with real limitations (like loss of seniority), and is not meant to set a general precedent.

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

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