Application for Public Employment: Eligibility conditions determined on the last date for submitting applications.

The applicant, Prabeen Kumar Mahanta, applied online for the post of Gramin Dak Sevak on February 9, 2023, declaring his category as OBC.

Although he belonged to the SEBC category in the State of Orissa, he uploaded an SEBC certificate and applied for an OBC certificate on May 19, 2023.

A notification for document verification was issued on May 13, 2023, requiring the applicant to appear with original documents by May 22, 2023.

On May 19, 2023, the applicant produced both SEBC and OBC certificates during verification.

However, his candidature was rejected on the same day because the data entered electronically regarding his community certificate did not tally with the documents produced.

The respondents stated that the OBC certificate was issued on May 19, 2023, which was after the application date (February 9, 2023).

1. Whether the rejection of the applicant's candidature for the post of GDS was illegal, improper, and unjust, given that his OBC certificate was issued after the last date of application but before document verification?

The court primarily applied the principle that eligibility conditions for public employment must be satisfied as of the last date for receiving applications.

This principle was affirmed by the Supreme Court in *Rakesh Kumar Sharma v. State (NCT of Delhi) and others (2013) 11 SCC 58*, which cited *U.P. Public Service Commission, U.P., Allahabad & Anr. v. Alpana, (1994) 2 SCC 723*, *Dr. M.V. Nair v. Union of India & Ors., (1993) 2 SCC 429*, and *Smt. Harpal Kaur Chahal v. Director, Punjab Instructions, Punjab & Anr., 1995 (Suppl) 4 SCC 706*.

Further reference was made to *Rekha Chaturvedi v. University of Rajasthan, 1993 Supp (3) SCC 168*, emphasizing that the date of selection is invariably uncertain, and the last date for applications is the relevant date for qualification scrutiny.

The court also relied on *Ashok Kumar Sharma v. Chander Shekhar (1997) 4 SCC 18*, which reiterated that eligibility must be judged with reference to the last date for filing applications.

The recent decision in *Sakshi Arya vrs The Rajasthan High Court & Ors (Civil Appeal No. 3957/2023, dated April 8, 2025)* further cemented that claims made by a candidate, including reservation certificates, must be valid as on the date of application or the last date of submission.

The court analyzed the facts in light of established legal precedents, emphasizing that eligibility conditions, including possession of valid reservation certificates, must be met by the last date of application.

The applicant declared his category as OBC on February 9, 2023, but the OBC certificate was issued on May 19, 2023, after the application deadline.

The court noted that there was no dispute that the applicant lacked the required OBC certificate on the application date.

Relying on the Supreme Court judgments, particularly *Rakesh Kumar Sharma* and *Sakshi Arya*, the court found that the respondents' rejection of the candidature was justified because the applicant did not possess the OBC certificate by the last date of application.

Allowing the applicant to proceed would violate the principle of equality and fairness to other candidates who might not have applied due to ineligibility on the cut-off date.

The Tribunal found no illegality in the respondents' rejection of the applicant's claim, as the OBC certificate was issued after the online application date.

Therefore, the applicant was not eligible for the post as he did not possess the required OBC certificate on or before the last date of application.