The Madhya Pradesh High Court has clarified that a candidate’s eligibility for reservation benefits in public employment cannot be denied solely because their caste certificate was issued by another state, provided the community is recognized as reserved in both jurisdictions. This judgment reinforces the constitutional mandate of non-arbitrariness and purposive interpretation of affirmative action, offering critical guidance to recruiting authorities across India.
Background & Facts
The Dispute
The petitioner, Smt. Vijeta Lohar, is a woman belonging to the Other Backward Class (OBC) community. She originally resided in a different state where she was issued a valid OBC caste certificate by the competent authority. After marrying a permanent resident of Madhya Pradesh, she shifted her residence and obtained a domicile certificate in accordance with state policy. She applied for the post of Uchha Madhyamik Shikshak under the OBC category, qualified in the written examination, and was called for document verification.
Procedural History
- 2018: Petitioner qualified the High School Teacher Eligibility Test (HTET)
- 2022: Application submitted for teaching posts under Madhya Pradesh School Education Service (Teaching Cadre) Recruitment Rules, 2018
- July 2022: Candidature cancelled by the Department of Tribal Affairs without show-cause notice or hearing, on grounds of non-submission of a Madhya Pradesh-issued caste certificate
- August 2022: Writ petition filed before the Madhya Pradesh High Court, Indore
Relief Sought
The petitioner sought quashing of the cancellation order, declaration that her OBC certificate issued by another state is valid for reservation purposes in Madhya Pradesh, and direction for her appointment with consequential benefits.
The Legal Issue
The central question was whether the rejection of a candidate’s candidature for a reserved post, solely on the ground that the caste certificate was issued by a competent authority outside Madhya Pradesh, violates Article 14 and Article 16 of the Constitution, in the absence of any express condition in the recruitment rules or advertisement.
Arguments Presented
For the Petitioner
The petitioner’s counsel relied on Dr. Alka Singh v. State of M.P. and Indra Sawhney v. Union of India, arguing that reservation is a beneficial provision requiring liberal interpretation. She contended that marriage does not render a person a migrant for reservation purposes, and that denying recognition to a validly issued caste certificate from another state - where the community is also recognized as reserved - is arbitrary and discriminatory. She emphasized that the advertisement did not mandate a state-specific certificate.
For the Respondent/State
The State contended that the recruitment rules and circulars require caste certificates to be issued by Madhya Pradesh authorities, and that the petitioner had falsely declared herself as a domicile. It argued that the Tehsildar had rightly rejected her caste certificate application, and that she had not exhausted alternative remedies like appeal. The State further claimed that local norms must prevail to prevent misuse of reservation benefits.
The Court's Analysis
The Court undertook a meticulous review of the recruitment rules, the advertisement, and binding precedents. It found no express clause in the Madhya Pradesh School Education Service (Teaching Cadre) Recruitment Rules, 2018, or in the advertisement, requiring a caste certificate issued exclusively by Madhya Pradesh authorities. The absence of such a condition rendered the rejection arbitrary.
"In absence of any express condition of ineligibility; the matter necessarily stands on a different footing."
The Court held that the doctrine of legitimate expectation, grounded in Article 14, prohibits changing the rules of selection after the process has commenced. Citing K. Manjusree v. State of Andhra Pradesh and Tej Prakash Pathak & Ors. v. Rajasthan High Court, it emphasized that candidates participate in recruitment on the basis of published criteria, and introducing new conditions at the verification stage undermines fairness.
The Court further relied on Indra Sawhney to affirm that reservation is a remedial, transient mechanism meant to correct historical injustice. Denying its benefits on technical grounds - such as the issuing state - defeats its constitutional purpose. The Court distinguished Bedanga Talukdar v. Saifudaullah Khan, noting that the rule of strict compliance applies only when conditions are explicitly stated.
It also affirmed the precedent in Dr. Alka Singh, which held that a woman who marries into Madhya Pradesh and belongs to a community recognized as OBC in both states cannot be treated as a migrant for reservation purposes. The Court concluded that the petitioner’s caste certificate, issued by a competent authority in another state, must be accepted for eligibility determination if the community is recognized as reserved in both states.
The Verdict
The petitioner won. The Court held that reservation eligibility cannot be denied solely on the ground that a caste certificate was issued by another state, provided the community is recognized as reserved in both jurisdictions. The impugned order was quashed, and the State was directed to verify the petitioner’s caste status and proceed with appointment, including consequential benefits, within 60 days.
What This Means For Similar Cases
Caste Certificate Validity Is Not Territorially Restricted
- Practitioners must now challenge rejections based on the issuing state of a caste certificate where the community is recognized as reserved in both states
- Recruitment authorities must verify recognition status across states, not merely the certificate’s origin
- Candidates with inter-state marriages are entitled to claim reservation benefits without reapplying for a new certificate if the community is recognized in both states
No New Conditions After Advertisement
- Any eligibility condition not explicitly stated in the advertisement or rules cannot be introduced during document verification
- Authorities must strictly adhere to published criteria; deviations amount to arbitrariness under Article 14
- Legal challenges can be framed on the doctrine of legitimate expectation when rules are changed mid-process
Reservation Must Be Interpreted Liberally
- Courts will favor purposive interpretation of reservation provisions to prevent exclusion on technicalities
- Rejection on grounds of procedural non-compliance without substantive inquiry is unsustainable
- This judgment strengthens the position that reservation is a constitutional remedy, not a privilege subject to bureaucratic discretion
