Bombay HC Upholds Aug 22, 2025 Degree Cutoff, Rejects 2026 Graduates’ Bid To Apply For Maharashtra Civil Judge Exam

In brief

The question

Whether the transitional directions in Bhumika Trust made all law graduates eligible to apply for the recruitment, including graduates who obtained their degrees after 22 August 2025.

The court held

The Court held that the corrigendum complied with the Supreme Court’s directions and found no basis to permit the petitioners, whose degrees were obtained after 22 August 2025, to apply under the recruitment in question.

It also directed

Both petitions were dismissed and the Rule discharged.

01Facts

The petitioners obtained law degrees in 2026 and enrolled as advocates on 20 June 2026.

pp. 2–4

They sought permission to apply for the Civil Judge (Junior Division) and Judicial Magistrate First Class Preliminary Examination pursuant to Advertisement No. 013/2026.

pp. 2–4

A corrigendum dated 23 October 2026, issued following the Supreme Court’s decision in Bhumika Trust v. Union of India, invited applications from eligible law graduates who had obtained their degrees before 22 August 2025, and treated certain candidates as having completed one year of active practice.

pp. 2–4

The petitioners challenged the exclusion of later graduates and sought permission to apply

pp. 2–4

02Issues

i.Whether the transitional directions in Bhumika Trust made all law graduates eligible to apply for the recruitment, including graduates who obtained their degrees after 22 August 2025.

pp. 8–9, 21

ii.Whether the MPSC’s corrigendum, which limited the relevant category to graduates who obtained their degrees before 22 August 2025, was inconsistent with the Supreme Court’s directions.

pp. 3–4, 21–22

03Law Applied

In All India Judges Association v. Union of India (2025), the Supreme Court restored a three-year practice requirement for candidates seeking appointment as Civil Judge (Junior Division), with practice calculated from provisional enrolment and supported by certification.

pp. 12–13

In Bhumika Trust v. Union of India, 2026 SCC OnLine SC 1687, the Supreme Court prescribed transitional arrangements for recruitment notifications issued after the review judgment and up to 31 March 2027: law graduates could apply notwithstanding the three-year requirement, but candidates were deemed to have completed one year of active practice in light of the time elapsed since the review judgment; appointment and subsequent training and clerkship would account for the remaining periods.

pp. 5–8

For recruitment notifications issued on or after 1 April 2027, the directions required at least one year of actual practice, supported by the prescribed certificate.

pp. 7–8

04Reasoning

The Court read the transitional direction permitting “all law graduates” to apply together with its accompanying statement that, because more than one year had elapsed since the review judgment, “such candidates” would be deemed to have completed one year of active practice.

pp. 16–21

Reading the direction as a whole and in light of Bhumika Trust’s reasoning, the Court held that the deemed period did not remove the one-year practice requirement or extend eligibility to every newly graduated candidate irrespective of the relevant date.

pp. 16–21

It also rejected the petitioners’ proposed distinction between “law graduates” and “candidates,” and considered the future-recruitment directions requiring one year of actual practice consistent with that interpretation

pp. 16–21