Candidates cannot reopen recruitment by correcting false bonus-mark declarations after repeated correction opportunities.

The Madhya Pradesh Employees Selection Board conducted recruitment for Primary Teachers, including posts reserved for candidates possessing a Rehabilitation Council of India (RCI)-recognised Special D.El.Ed. qualification.

Under Clause 7.7 of the applicable Rule Book, eligible candidates were entitled to 5% bonus marks upon declaring the requisite qualification in the online application.

The appellants had selected “YES” under the relevant RCI qualification option, although they did not possess the qualifying RCI diploma, and were consequently awarded the 5% bonus marks.

The recruitment rules required candidates to verify the correctness of their applications and provided a correction window.

Additional opportunities to correct the relevant declaration were subsequently provided, including pursuant to the decision in Deepak Parmar v. State of Madhya Pradesh, W.P. No. 42759 of 2025.

The appellants did not rectify their declarations during any of the available correction periods.

After the result and merit list were declared, they sought deletion of the bonus marks and consideration of their candidature on the basis of their actual marks, contending that the incorrect declaration was inadvertent.

The learned Single Judge, by order dated 6 May 2026 in W.P. No. 12970 of 2026 and connected matters, directed verification of the RCI qualifications and revision of the merit list, while declining to permit candidates to reopen or correct their applications after the expiry of the correction opportunities.

The appellants challenged that decision under Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005.

Whether candidates who incorrectly declared possession of an RCI-recognised Special D.El.Ed. qualification could seek deletion of the resulting 5% bonus marks and reconsideration of their candidature after the expiry of the prescribed and additional correction windows?

Whether permitting such post-result corrections would impermissibly disturb the final merit list and prejudice candidates who had furnished correct information?

Whether the appellants’ incorrect declarations could be treated as bona fide inadvertent mistakes, or constituted false representations disentitling them to equitable relief?

The appeals were governed by Section 2(1) of the Madhya Pradesh Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005, which permits an intra-court appeal from the judgment of a Single Judge.

Clause 7.7 of the Recruitment Rule Book restricted the 5% bonus marks to candidates possessing an RCI-recognised Special D.El.Ed. qualification and required candidates to verify the accuracy of their online declarations.

The Court applied the principle that a candidate must comply with the recruitment rules and cannot seek alteration of a material declaration after the prescribed correction period and completion of the selection process.

It further applied the settled doctrine that “fraud vitiates all solemn proceedings” and “fraud unravels everything,” relying on Mahesh Kumar Batham v. Life Insurance Corporation of India, W.A. No. 278 of 2025, and the Supreme Court authorities cited therein, including R. Ravindra Reddy v. H. Ramaiah Reddy, (2010) 3 SCC 214, K.D. Sharma v. SAIL, (2008) 12 SCC 481, and DDA v. Skipper Construction, (2007) 15 SCC 601.

The Court distinguished Vashist Narayan Kumar v. State of Bihar, 2024 INSC 2, and Jyoti Yadav v. State of Uttar Pradesh, W.P. (C) No. 322 of 2021, as decisions rendered on materially different facts or under different recruitment schemes.

The Court adopted the reasoning of the coordinate Bench in Survendra v. State of Madhya Pradesh, W.A. No. 1769 of 2026 and connected matters, holding that the same legal principles applied mutatis mutandis to the present appeals.

The appellants’ declarations were material because they directly resulted in the award of 5% bonus marks.

Although the appellants claimed that they merely wished to surrender the wrongly awarded marks, permitting such a correction after declaration of the result would require alteration of the final merit list and could affect the inter se ranking and rights of other candidates.

The Court emphasised that the candidates had multiple opportunities to correct their applications—initially during the prescribed correction period and subsequently through further windows extending up to February 2026—but failed to do so.

In those circumstances, the Court declined to characterise the declarations as harmless clerical mistakes.

The continued failure to correct the declarations, despite repeated opportunities, supported the conclusion that the appellants had obtained or attempted to obtain an undue advantage through misrepresentation.

Reopening the recruitment process would undermine certainty and fairness in public employment and prejudice candidates who had submitted accurate information.

Such conduct could not be treated as a mere inadvertent error, particularly where repeated correction opportunities had been provided.

Applying the coordinate Bench’s decision in Survendra, the Court found no error in the Single Judge’s order and dismissed all the connected writ appeals.

A photocopy of the common order was directed to be placed in each connected appeal.