An EWS certificate issued after the application cutoff cannot support reservation eligibility.

The petitioner applied for recruitment as a female Constable in the Delhi Police under the EWS category. She scored 60.18683 marks—above the EWS cut-off of 53.400009 but below the Unreserved cut-off of 61.04952.

The recruitment notice required an EWS certificate to be issued on or before the closing date for applications, 30 September 2023; the petitioner’s certificate, though relating to the relevant financial year, was issued on 5 January 2024.

At document verification, she agreed in writing to have her candidature considered under the Unreserved category, but did not disclose that concession in her application before the Central Administrative Tribunal or in her writ petition.

The Tribunal dismissed her OA, and she challenged that decision before the Delhi High Court.

Whether the petitioner could claim EWS consideration when her certificate was issued after the closing date specified in the recruitment notice.

Whether the petitioner was entitled to relief despite failing to disclose her written agreement, at document verification, to be considered under the Unreserved category.

A candidate seeking reservation must comply with the eligibility and documentary requirements prescribed for the recruitment process. Clause 6.4 of the recruitment notice required the EWS certificate to be issued on or before the closing date and provided that a later-issued certificate would not be accepted, even if valid for the relevant financial year.

This requirement was consistent with paragraph 5.3 of the Department of Personnel and Training Office Memorandum dated 31 January 2019 and Note 2 to Point 5 of Delhi Police Standing Order HRD/04/2022, which tied the relevant eligibility date to the closing date for applications.

Under the clean-hands principle, suppression of a material fact may disentitle a litigant to relief, including before the Central Administrative Tribunal, whose jurisdiction is analogous to that of the High Court under Article 226.

The Court also relied on Mohit Kumar v. State of U.P., 2025 SCC OnLine SC 1125, concerning compliance with recruitment-notice requirements, and Divya v. Union of India, (2024) 1 SCC 448, upholding a prescribed cut-off date for possession of an EWS certificate.

The petitioner’s certificate was issued after the prescribed closing date, so it did not meet Clause 6.4, notwithstanding that it related to the relevant financial year.

The Court found no conflict between that clause and any applicable statutory rule; rather, the clause accorded with the relevant administrative instructions.

The Court further held that the petitioner’s failure to disclose her written agreement to Unreserved-category consideration independently weighed against granting relief.

The decisions in Mohit Kumar and Divya supported enforcing clear recruitment requirements and cut-off dates; the Court distinguished other authorities cited by the petitioner because they did not concern a comparable express stipulation.

It dismissed the writ petition.