An unsuccessful candidate below the prescribed cut-off cannot claim appointment absent proven illegality in selection.

The applicant participated in the recruitment process initiated by the Puducherry Police Department for 100 posts of Women Police Constable pursuant to notification dated 5 December 2014.

After qualifying in the physical stages, she appeared in the written examination held on 6 September 2015. Her name was not included in the provisional selection list published on 11 September 2015.

Through the Right to Information Act, she obtained her examination marks and the post-based roster on 21 September 2016.

She challenged the selection of Respondents 4 to 13 against the General/Unreserved category, alleged improper preparation of the post-based roster, and sought appointment to the post of Women Police Constable.

The respondents contended that the applicant had secured only 80 marks out of 200, whereas the cut-off was 93 marks for the General category and 92 marks for the Scheduled Caste category.

Whether the candidates belonging to reserved categories who were selected under the General/Unreserved category ought instead to have been adjusted against reserved vacancies, thereby creating a vacancy for the applicant?

Whether the post-based roster and the provisional selection list were prepared in violation of the applicable reservation principles and recruitment rules?

Whether the applicant was entitled to appointment despite securing marks below the prescribed cut-off, and whether non-publication of a waiting list or immediate disclosure of unsuccessful candidates’ marks invalidated the selection process?

The Tribunal applied the Recruitment Rules framed under Article 309 of the Constitution, under which selection was to be made through the prescribed physical and written examination process, with the written examination determining comparative merit.

It applied the principle that a reserved-category candidate selected on open merit may be counted against a General/Unreserved vacancy, but a candidate who has availed reservation-related concessions such as age relaxation is ordinarily treated as selected against the reserved quota.

The Tribunal further applied the settled rule that mere participation in a recruitment process does not confer a right to appointment and that an unsuccessful candidate cannot challenge the selection merely because the result is adverse, absent proof of illegality, arbitrariness, mala fides, or violation of the governing rules.

Relying on Dugapur Steel Plant & Others v. Bidhan Chandra Chowdhury & Others, 2026 INSC 459, it reiterated that a select-list candidate has no indefeasible right to appointment and that, where neither the rules nor the advertisement requires publication of all candidates’ marks, non-publication of such marks does not by itself invalidate the selection.

The Tribunal found that the recruitment was conducted in accordance with the notified procedure and the applicable Recruitment Rules.

The select list comprised candidates distributed across the notified categories, and Respondents 4 to 13 were shown under the General category rather than being adjusted against the Scheduled Caste quota.

The candidates placed in the Scheduled Caste category had availed age relaxation and other reserved-category benefits; therefore, the Tribunal held that they were properly counted against the Scheduled Caste quota and could not be treated as General-category candidates.

Independently, the applicant lacked the requisite merit: her score of 80 marks was below both the General cut-off of 93 and the Scheduled Caste cut-off of 92.

The Tribunal also found no rule requiring publication of a waiting list or immediate disclosure of marks obtained by all unsuccessful candidates, and held that the applicant had not established any specific illegality, arbitrariness, procedural irregularity, or violation of reservation rules.

It held that Respondents 4 to 13 were properly selected against the General/Unreserved category, that the post-based roster and selection list disclosed no established illegality, and that the applicant was not entitled to appointment because she had failed to meet the applicable cut-off marks.

The Original Application was accordingly dismissed as devoid of merit, with no order as to costs.