Sakshi Arha v. The Rajasthan High Court
Background
Several OBC/MBC-category candidates cleared the Rajasthan Civil Judge recruitment exam, but their reserved-category certificates had been issued years before the application, and a notice issued after the exam ("Subsequent Notice") required certificates to be issued within a set window before the application deadline. Because their certificates didn't meet this window, they were excluded from the interview list, prompting a series of writ petitions that eventually split a 2-Judge Bench and were referred to a 3-Judge Bench.
Decision Breakdown
The Court held that when an advertisement is silent about a cut-off date for reserved-category certificates, the well-settled legal position is that eligibility (including certificate validity) is judged as of the last date for submitting applications. Reservation-category certificates (unlike SC/ST certificates) are only valid for one year and can be extended by affidavit for up to three years under the relevant state circulars: none of the appellants met even this extended window as of the application deadline. The Court held the High Court's "Subsequent Notice" cut-off was lawful and consistent with prior circulars, and dismissed all the appeals.
Lesson Learnt
Reserved-category candidates must ensure their category certificates remain valid (renewed by affidavit if needed) as of the application deadline, not the date of selection. Courts strictly apply the "last date of application" as the cut-off when the advertisement itself is silent.