RAJASTHAN HIGH COURT v. RAJAT YADAV
Merit vs. Reservation: Supreme Court Upholds Inclusion of High-Scoring Reserved Category Candidates in General Category List, Ensuring Equality and Meritocracy in Public Employment.
Court: Supreme Court of India
Citation: 2025 INSC 1503
Decision Date: 19-12-2025
List of Laws
Constitution of India, Articles 14 and 16; Reservation Policy; Principle of Migration; Principle of Estoppel; Rajasthan District Courts Ministerial Establishment Rules, 1986; Rajasthan High Court Staff Service Rules, 2002
- Facts: The Rajasthan High Court administration appealed a decision by its Division Bench regarding the recruitment process for Junior Judicial Assistants/Clerk Grade-II. The recruitment involved a written test and a typewriting test. Several reserved category candidates scored higher than the general category cut-off but were not included in the general list for the typewriting test. The Division Bench ruled that reserved category candidates scoring higher than the general cut-off should be included in the general list, leading to the appeal.
- Procedural Posture: This case is a civil appeal before the Supreme Court of India, challenging the order of the Division Bench of the Rajasthan High Court, which allowed writ petitions filed by aggrieved candidates.
- Issue: Whether reserved category candidates, who have not availed any special concession and score higher than the cut-off marks for the general category in a written examination, are entitled to be considered in the general category merit list at the stage of shortlisting for the next stage of the selection process, and whether excluding them violates Articles 14 and 16 of the Constitution.
- Holding: The Supreme Court upheld the Division Bench's order, affirming that reserved category candidates who score higher than the general category cut-off are entitled to be considered in the general category merit list, provided they have not availed any special concession. The appeals were dismissed.
- Reasoning: The Court reasoned that excluding more meritorious reserved category candidates from the general category solely based on their category violates Articles 14 and 16 of the Constitution, emphasizing that the open category is not a quota but is open to all based on merit. The Court rejected the argument of "double benefit," stating that merit should be the primary criterion. It clarified that the principle of migration applies at every stage of assessment, not just the final merit list. The Court distinguished the case from previous rulings like Chattar Singh, where preliminary exam marks were not considered for final merit, emphasizing that in this case, the written exam was a substantive part of the selection process. The Court also noted that the principle of estoppel does not apply when there is a violation of constitutional principles.
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