Facts
The applicant, currently serving as a Mali (Gardener) with the Delhi Development Authority (DDA), participated in the Limited Departmental Competitive Examination (LDCE) 2025 for promotion to the post of Junior Secretarial Assistant (JSA)/LDC.
Source reference: para. 2Although the applicant qualified in the written examination result declared on 30.12.2025, he was not declared successful because he failed to qualify the mandatory typing test.
Source reference: para. 2-3The applicant, being over 45 years of age, sought an exemption from the typing test by invoking Clause 2(1)(b) of the Department of Personnel and Training (DoPT) Office Memorandum (OM) dated 22.04.2015.
Source reference: para. 3The respondent (DDA) argued that the applicant does not belong to the feeder cadre (Multi-Tasking Staff) for the post of JSA and that the typing test is an essential condition for the LDCE, distinct from regular promotions.
Source reference: para. 4Issues
1. Whether a candidate participating in the Limited Departmental Competitive Examination (LDCE) is entitled to age-based exemption from the typing test under DoPT OM dated 22.04.2015.
Source reference: para. 3-42. Whether the relaxations applicable to candidates in a regular promotion channel can be extended to candidates from a non-feeder cadre appearing via LDCE.
Source reference: para. 8Law Applied
DoPT OM dated 22.04.2015, specifically Clause 2(1)(b), which provides for exemption from the requirement of passing a typing test for certain candidates upon attaining the age of 45 years.
Source reference: para. 3DoPT OM dated 29.09.1992 regarding similar exemptions.
Source reference: para. 6The legal distinction between "regular promotion" within a feeder cadre (where exemptions may apply) and selection via "Limited Departmental Competitive Examination" (LDCE), where qualifying prescribed tests is an essential eligibility condition.
Source reference: para. 4, 8Reasoning
The Tribunal found that the applicant’s reliance on the DoPT OM was misplaced due to the specific nature of his participation in the selection process.
Source reference: para. 4, 8The court noted that the applicant is a Mali, which is not the feeder cadre for the post of JSA; he was only permitted to participate in the LDCE as a special provision.
Source reference: para. 4, 8The Tribunal reasoned that while exemptions from typing tests might apply to regular promotions within a feeder cadre (as seen in the case of 17 MTS employees), the typing test remains an "essential condition" for success in the LDCE.
Source reference: para. 4, 5, 8The Tribunal distinguished the applicant's cited precedent (OA No. 2294/2019), noting that the current case involves an LDCE candidate rather than a person seeking promotion within their own cadre.
Source reference: para. 8The court determined that there is no legal provision allowing for the waiver of an essential exam component in a competitive departmental examination.
Source reference: para. 8Holding
The Tribunal answered the issues in the negative, holding that the relief sought was not permissible under the applicable recruitment rules and departmental guidelines.
The court held that age-based exemptions for typing tests do not apply to the LDCE category for candidates outside the feeder cadre.
Source reference: para. 8-9Accordingly, the Original Application (OA) was dismissed at the admission stage.
Source reference: para. 9Original Court PDF
MAHESH KUMARvsDELHI DEVELOPMENT AUTHORITY
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