Madhya Pradesh High Court

Age relaxation for multiple categories cannot be claimed cumulatively unless expressly provided by statutory recruitment rules.

Shalik Ram Yadav vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: April 27, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner, an Other Backward Class (OBC) candidate with a 45% locomotor disability, challenged the age criteria in an advertisement issued on 10/03/2026 for the post of Assistant District Public Prosecution Officer.

Source reference: para. 2-3

The Petitioner’s date of birth is 10/01/1981, making him 45 years, 11 months, and 21 days old as of the cut-off date, 01/01/2027.

Source reference: para. 2

The advertisement stipulated a maximum age limit of 45 years after all relaxations.

Source reference: para. 4

The Petitioner sought to quash the 01/01/2027 cut-off date, requesting it be shifted to 01/01/2026, and prayed for a cumulative age relaxation (5 years for OBC plus 5 years for disability) and a 3-year "Covid period" extension.

Source reference: para. 1, 5
02

Issues

1. Whether the cut-off date for age determination (01/01/2027) was legally valid under the relevant service rules.

Source reference: para. 16-17

2. Whether a candidate can claim age relaxation cumulatively under multiple categories (OBC and Disabled) beyond the maximum prescribed limit of 45 years.

Source reference: para. 7, 11

3. Whether the High Court can interfere with the eligibility criteria or cut-off dates prescribed by an employer.

Source reference: para. 12-13
03

Law Applied

Rule 8 of the M.P. Public Prosecution (Gazetted) Service Recruitment Rules, 1991, which mandates that age eligibility be satisfied on the 1st of January following the commencement of selection.

Source reference: para. 16-17

Union of India v. Pushpa Rani (2008) 9 SCC 242, establishing that prescribing qualifications and recruitment methodology is the exclusive domain of the employer.

Source reference: para. 13

Bhupinderpal Singh v. State of Punjab (2000) 5 SCC 262, which holds that if a date is appointed by rules or advertisement, it must be upheld.

Source reference: para. 15

Principle from the Full Bench decision in Maharashtra Public Service Commission v. Sunil Santosh Pawar 2018 SCC Online Bom. 6881, which prohibits cumulative age relaxation across categories unless explicitly permitted by rules.

Source reference: para. 20-21
04

Reasoning

The Court observed that the cut-off date of 01/01/2027 was strictly in accordance with Rule 8 of the 1991 Recruitment Rules, leaving no room for judicial interference.

Source reference: para. 17-18

Regarding the claim for 10 years of cumulative relaxation (OBC + Disability), the Court ruled that in the absence of specific statutory provisions or executive instructions, a candidate may opt for the most beneficial single relaxation but cannot claim them cumulatively to exceed the absolute cap of 45 years set by the employer.

Source reference: para. 11, 21

The Court emphasized that judicial review is limited to cases of patent arbitrariness or violation of constitutional/statutory provisions; since the Petitioner failed to prove such violations, the employer's prerogative to set eligibility criteria remains intact.

Source reference: para. 12-14
05

Holding

The Court holding that the Petitioner was ineligible as his age exceeded the 45-year maximum limit as of the statutory cut-off date.

The Court affirmed that (i) the cut-off date was legally fixed per statutory rules; (ii) cumulative age relaxation across two categories is not a right unless expressly provided; and (iii) the judiciary cannot sit in appeal over the employer's policy decisions regarding recruitment criteria.

Source reference: para. 13, 21-22

The Court dismissed the writ petition. All requested reliefs were denied.

Source reference: para. 22
Madhya Pradesh High Court

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Shalik Ram YadavvsThe State Of Madhya Pradesh

Madhya Pradesh High Court · April 27, 2026

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