Candidates cannot alter declared recruitment categories after the correction period merely because the error was bona fide.

The petitioners participated in the Madhya Pradesh Police Constable Recruitment Test, 2023 conducted by the Madhya Pradesh Employees Selection Board.

Although they belonged to the Scheduled Tribe category, they inadvertently selected “Yes” in the online application column relating to Ex-serviceman/Surplus Employee/Work Charge and Contingency Employee/NCC, despite not belonging to that category.

They claimed that the error was bona fide, did not confer any undue advantage, and that they had secured 143.28 and 154.59 marks against the stated ST/Open cut-off of 140.49 marks.

They sought correction of the online application and appointment on the basis of their actual ST category.

The respondents opposed the petition, contending that the advertisement provided a specific correction period, which the petitioners did not utilise, and that alteration after substantial progress of the recruitment process was impermissible.

The petitioners relied upon Vashist Narayan Kumar v. State of Bihar and Himanshu Samadhia v. State of Madhya Pradesh .

1. Whether the petitioners could seek alteration of the special-category declaration in their online applications after expiry of the prescribed correction period and after the recruitment process had substantially progressed.

2. Whether a bona fide and allegedly inconsequential mistake in selecting the special-category option entitled the petitioners to consideration under their actual Scheduled Tribe category and appointment.

3. Whether the High Court could exercise jurisdiction under Articles 226/227 of the Constitution to direct such alteration contrary to the prescribed recruitment procedure.

The Court applied the principle that recruitment must be conducted strictly in accordance with the advertisement and applicable recruitment rules, and that a candidate cannot ordinarily alter material particulars after submission of the application and expiry of the prescribed correction period.

Relying on Bedanga Talukdar v. Saifudaullah Khan , (2011) 12 SCC 85, the Court held that recruitment conditions must be uniformly followed and relaxation cannot be claimed as a matter of right in the absence of an enabling provision.

Relying on Madan Lal v. State of J , (1995) 3 SCC 486, the Court reiterated that a candidate participating in a selection process must abide by its governing conditions and cannot subsequently seek alteration to secure an advantage.

The Court further held that bona fide error, absence of actual benefit, or marks above the cut-off does not create an enforceable right to correction after the prescribed stage, particularly where such correction may affect the recruitment process or the rights and ranking of other candidates.

The Court found that the petitioners had admittedly selected “Yes” against the relevant special-category option and had been given an opportunity to correct their applications within the prescribed period, but no correction was made.

Their request was not for correction of an innocuous typographical detail; it would change the basis on which their candidature was processed.

The fact that they allegedly obtained marks above the ST/Open cut-off did not permit the Court to reopen or modify their candidature after the selection process had proceeded on the basis of the submitted applications.

The authorities’ refusal to alter the applications was therefore consistent with the requirement of uniform treatment of all candidates and did not constitute arbitrariness, perversity, or violation of any legal or constitutional right.

The Court distinguished Vashist Narayan Kumar and Himanshu Samadhia as decisions based on their peculiar facts, which did not confer an automatic right of post-deadline correction in the present case.

It held that the petitioners had no legal right to alter the special-category declaration after expiry of the correction period and after substantial progression of the recruitment process, notwithstanding the asserted bona fide nature of the mistake or their marks above the cut-off.

The writ petition under Articles 226/227 was dismissed, and no order as to costs was made.