Facts
The respondent applied for an AIIMS Driver Ordinary Grade post as an OBC-NCL candidate. He ranked fifth in the written examination, securing 161 marks out of 200.
Source reference: p. 2–3, para. 3The advertisement required an OBC-NCL certificate issued between 1 April 2020 and 31 March 2021, the financial year in which the vacancies were advertised.
Source reference: p. 3, p. 9–10, paras. 4, 20.3After initially providing an older certificate, the respondent was given 15 days by AIIMS’s letter of 7 September 2022 to produce a qualifying certificate. Within that period, he submitted a certificate dated 13 September 2022 stating that he belonged to the OBC-NCL category during the 2020–2021 financial year.
Source reference: p. 4–6, paras. 7–10AIIMS rejected his candidature because the certificate had not itself been issued during the specified period.
Source reference: p. 7, para. 11The Central Administrative Tribunal allowed his application, relying on *A.I.I.M.S. v. Ravi Kumar*, and directed that the certificate be treated as valid; AIIMS challenged that decision under Article 226.
Source reference: p. 7, paras. 12–14Issues
Whether the respondent’s OBC-NCL certificate, issued in September 2022 but certifying his status for financial year 2020–2021, could be accepted despite the advertisement’s requirement that the certificate be issued during that financial year.
Source reference: p. 9–12, paras. 20.3–20.13Whether AIIMS could reject the certificate after granting the respondent an additional 15 days to produce it, particularly where the respondent’s OBC-NCL status and the issuing authority’s competence were undisputed.
Source reference: p. 11–12, paras. 20.8–20.12Law Applied
Clause 10(i) of the advertisement required OBC-NCL candidates to submit a valid certificate and specified an issuance window of 1 April 2020 to 31 March 2021; the Court construed that requirement in light of its stated purpose of establishing the candidate’s OBC-NCL status for the relevant financial year.
Source reference: p. 9–10, paras. 20.1, 20.3–20.5The Court noted that OBC-NCL status may fluctuate, unlike SC/ST status, and referred to *Sakshi Arha v. Rajasthan High Court*, 2025 SCC OnLine SC 757, on that distinction.
Source reference: p. 10, para. 20.4It also referred to the reservation principles in *Indra Sawhney v. Union of India*, 1992 Supp (3) SCC 217.
Source reference: p. 11, para. 20.6The Court assessed the Tribunal’s decision within its Article 226 jurisdiction and declined interference where the decision did not warrant it.
Source reference: p. 7, p. 13, paras. 14, 21–22Reasoning
The Court held that the certificate’s date of issuance was not, on these facts, a sufficient basis for rejection. AIIMS had extended the time for submission, and the respondent produced the certificate within that period; rejecting it for not having been issued during a period that had ended more than a year earlier would be unfair.
Source reference: p. 11, para. 20.8The certificate established the respondent’s OBC-NCL status for 2020–2021, thereby serving the purpose of the advertisement’s issuance-window requirement. The issuing authority’s competence and the respondent’s status were not disputed.
Source reference: p. 11–12, paras. 20.12–20.13The Court also took account of the practical difficulty of obtaining certificates during the COVID-19 pandemic.
Source reference: p. 12, para. 20.10Holding
The Court dismissed AIIMS’s writ petition and declined to interfere with the Tribunal’s judgment.
It directed AIIMS to process the respondent’s candidature in accordance with the Tribunal’s directions within eight weeks.
Source reference: p. 13, para. 23Original Court PDF
All India Institute Of Medical SciencesvsGirdhari Lal Jakhar
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