UNION OF INDIA v. G. KIRAN
Reserved Category Candidates and Unreserved Vacancies: Relaxation at Any Stage Disqualifies for General Category Allocation.
Court: Supreme Court of India
Citation: 2026 INSC 15
Decision Date: 06-01-2026
List of Laws
The Constitution of India; Exam Rules, 2013; Cadre Allocation Policy (dated 10th April 2008, amended on 21st April 2011)
- Facts: A reserved category (SC) candidate, Respondent No. 1, availed relaxation in the Preliminary Examination for the Indian Forest Service (IFS) exam. While he scored lower than the general category cut-off in the Preliminary Exam, he scored higher in the Main Examination and secured a higher rank than a general category candidate, Respondent No. 3. The dispute arose regarding cadre allocation, specifically for a 'General Insider' vacancy in Karnataka. Respondent No. 1 claimed entitlement to this vacancy, while the Union of India allocated it to Respondent No. 3.
- Procedural Posture: Respondent No. 1 filed an Original Application before the Central Administrative Tribunal (CAT), which was allowed. The CAT directed allocation of the General Insider vacancy to Respondent No. 1. Respondent No. 3 and the Union of India challenged this before the High Court of Karnataka, which dismissed their petitions, affirming the CAT's order. The Union of India and Respondent No. 3 then appealed to the Supreme Court.
- Issue: Can a reserved category candidate, who availed relaxation in the Preliminary Examination but later performed better than general category candidates in the Main Examination, be considered for allocation against an unreserved vacancy, specifically a 'General Insider' vacancy?
- Holding: No, a reserved category candidate who availed relaxation at any stage of the examination cannot be considered for allocation against an unreserved vacancy. The Supreme Court set aside the judgments of the Tribunal and the High Court.
- Reasoning: The Court analyzed the Exam Rules, 2013 and the Cadre Allocation Policy. It emphasized that Rule 14 of the Exam Rules bars the adjustment of reserved category candidates against unreserved vacancies if they availed relaxation at any stage of the eligibility or selection criteria. The Court stated that the Preliminary Examination, though a screening test, is an integral stage of the examination. Availing relaxed standards at this stage disqualifies a candidate from being considered under "General Standards" for unreserved vacancies. The Court relied on previous judgments, including Deepa E.V. v. Union of India, to support its view that availing relaxation at any stage precludes consideration for unreserved seats. The Court concluded that the 'General Insider' vacancy was rightfully allocated to Respondent No. 3, who qualified on general standards throughout the selection process.
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