A reservation certificate meeting eligibility criteria cannot be rejected solely for a format defect.

The applicant applied for the post of Assistant Director (E&S) under the Pahadi Speaking People (PSP) category and the physically handicapped (PHC) sub-category. He qualified in the written examination. The PSC later rejected his candidature because his PSP certificate contained a handwritten condition tying its validity to an annual income ceiling of ₹8 lakh, and was said not to be in the prescribed format.

An income certificate issued before the application cut-off showed family income of ₹6,41,100; the Tehsildar subsequently verified the PSP certificate and its basis.

The applicant challenged the rejection. During the proceedings, he was permitted to sit the viva voce at his own risk, and the PSC placed his merit at 313 in the PSP/PHC (locomotor) category.

The Tribunal also allowed amendments to the application seeking a direction for recommendation and appointment.

1. Whether the PSC was required to accept the applicant’s PSP certificate despite its conditional endorsement and the objection that it was not in the prescribed format.

2. Whether, in light of the income certificate and the issuing authority’s verification, the applicant’s candidature could be rejected on that ground.

The advertisement required candidates seeking reservation to possess a valid category certificate by the cut-off date.

The Tribunal applied the principle stated in Priyanka Rakwal v. UT of J&K & Others, WP(C) No. 2834 of 2025, decided 6 February 2026: where a certificate issued by a competent authority establishes substantive eligibility for reservation, it should not be rejected solely for a defect in format, particularly where the issuing authority clarifies the matter; substance, rather than form, governs.

The Tribunal found that the PSP certificate had been issued by the competent Tehsildar and that the contemporaneous income certificate showed family income below the ₹8 lakh ceiling. The Tehsildar’s reply and supplementary affidavit confirmed the certificate’s basis and genuineness; the handwritten condition was therefore unnecessary in light of the income certificate.

Applying Priyanka Rakwal, the Tribunal held that the certificate’s alleged format defect did not justify rejection where the substantive eligibility requirement was met and the issuing authority had verified the certificate.

It also noted the applicant’s recorded merit and 40% permanent locomotor disability.

It directed the PSC to recommend the applicant to the Government for appointment as Assistant Director (E&S) under the PSP/PHC (locomotor) category within two weeks of receiving the order, and directed the Government to issue the appointment order within the following three weeks.

No order as to costs was made.