The State of Bihar v. Madhu Kant Ranjan
Background
A candidate applied for the post of Constable in the Bihar Police in response to a 2004 advertisement that offered extra marks for holding an NCC 'B' certificate, but he did not submit a copy of that certificate along with his original application. He scored only 12 marks (missing the 5 bonus marks) and was not selected, even though a later select list in 2007 (after he submitted the certificate following his physical test) showed him with 17 marks. After years of litigation, the Patna High Court's Division Bench eventually condoned a 3-year delay and ordered the State to appoint him based on the 17-mark list. The State of Bihar appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that eligibility and bonus-mark criteria must be assessed strictly as per the documents submitted along with the original application by the prescribed cut-off date, not documents submitted years later. It found that the candidate's claim, made for the first time in the second round of litigation, that he had originally submitted the NCC certificate was an afterthought, contradicted by his own earlier writ petition which contained no such plea. Since he had only produced the certificate after the physical test and years after the application deadline, he was not entitled to the 5 bonus marks, and the High Court's Division Bench had erred in directing his appointment based on the later select list. The Supreme Court allowed the State's appeal and restored the order of the Single Judge dismissing the candidate's writ petition.
Lesson Learnt
In competitive recruitment, only the documents and qualifications actually submitted with the original application by the cut-off date count: a candidate cannot improve their claim years later, and courts will scrutinise whether a late-raised claim is consistent with what was pleaded earlier in the same litigation.