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Saurav Yadav v. The State of Uttar Pradesh

Miscellaneous Application · 2020 INSC 714Decided 18 Dec 2020
Miscellaneous Application No. 2641 of 2019
Justice Uday Umesh Lalit · Justice S. Ravindra Bhat · Justice Hrishikesh Roy

Background

This case arose from a long-running dispute over the 2013 Uttar Pradesh Police Constable recruitment, where female candidates from reserved social categories (like OBC and SC) who scored high enough marks to qualify for the "General/Open" category on pure merit were instead being counted only within their social-category quota, while the horizontal "women" quota in the open category was filled by other, less meritorious candidates. Applicants Sonam Tomar and Reeta Rani, and several similarly situated women, argued that U.P.'s approach wrongly excluded meritorious reserved-category women from open-category women's seats, contrary to earlier Supreme Court rulings on how horizontal (women, disabled, ex-servicemen etc.) reservation should interact with vertical (caste-based) reservation.

Decision Breakdown

The Supreme Court held that a woman candidate from a reserved social category who scores high enough to qualify for the "Open/General" category purely on merit cannot be denied that open-category seat merely because she also belongs to a social reservation category: horizontal reservations like "women" cut across vertical categories and must be applied within each vertical column, not used to exclude meritorious reserved-category candidates from open seats. The Court rejected the State's contrary interpretation as leading to irrational results where less meritorious candidates could leapfrog more meritorious ones. It directed that candidates like Sonam Tomar who scored above the cut-off of the last selected Open/General-category woman be offered employment as Constables, with a structured timeline for appointment, while clarifying that already-appointed candidates' positions would not be disturbed. A separate connected writ petition seeking absorption against unfilled vacancies was dismissed as the petitioners there did not meet the relevant merit threshold.

Lesson Learnt

In reserved public recruitment, a candidate's caste or social-category reservation does not disqualify them from being selected on pure merit against "Open/General" category seats (including the horizontal women's quota within it), denying such candidates their rightful open-category seat merely because they also hold a reservation status is unconstitutional.

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

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