Candidates cannot seek post-result correction after false eligibility declarations despite repeated correction opportunities.

The Madhya Pradesh Employees Selection Board conducted recruitment for 13,089 Primary Teacher posts, including 3,200 posts reserved for candidates holding an RCI-recognised Special D.El.Ed. qualification.

Clause 7.7 of the recruitment Rule Book granted such candidates 5% bonus marks upon declaring possession of the requisite qualification in the online application.

The appellants selected “YES” under Clause 7.7 despite not possessing the prescribed qualification, and were consequently awarded bonus marks.

The Writ Court directed verification of the claimed RCI qualifications and revision of the merit list by excluding ineligible candidates.

The appellants challenged the common order dated 06.05.2026 passed in W.P. No. 12970 of 2026 by filing appeals under Section 2(1) of the M.P. Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005.

Whether candidates who declared possession of an RCI-recognised Special D.El.Ed. qualification, received 5% bonus marks, and failed to correct the declaration during the prescribed correction opportunities could subsequently seek deletion of the bonus marks and reconsideration of their candidature?

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

Whether the appellants were entitled to appellate interference with the Writ Court’s order directing verification of qualifications and revision of the merit list?

The appeals were governed procedurally by Section 2(1) of the M.P. Uchcha Nyayalaya (Khand Nyayapeeth Ko Appeal) Adhiniyam, 2005.

Substantively, Clause 7.7 of the Employees Selection Board’s Rule Book restricted the 5% bonus marks to candidates possessing an RCI-recognised Special D.El.Ed. qualification and required candidates to verify the correctness of their online declarations.

The Court applied the principle that a recruitment process must retain certainty, finality and fairness, and that corrections cannot ordinarily be permitted after the result and merit list have been finalised where correction opportunities were expressly provided.

It further applied the settled doctrine that fraud or a false declaration vitiates proceedings, 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, and K.D. Sharma v. SAIL, (2008) 12 SCC 481.

The Court also followed Deepak Parmar v. State of Madhya Pradesh, W.P. No. 42759 of 2025, under which an additional correction window had been provided.

The Division Bench held that the Coordinate Bench’s decision in Survendra squarely covered the controversy and applied its reasoning mutatis mutandis.

The recruitment Rule Book clearly confined bonus marks to candidates possessing the specified RCI qualification, while requiring all candidates to verify their declarations.

The appellants had multiple opportunities to correct their applications despite these opportunities: the original correction window, a further window from 26.12.2025 to 10.01.2026 pursuant to Deepak Parmar, and a third special correction window from 04.02.2026 to 11.02.2026.

Because the appellants did not correct their applications despite these opportunities, the Court declined to treat the declarations as merely clerical or inadvertent mistakes.

It held that reopening the applications after declaration of results would disturb the inter se merit of candidates, unsettle the completed selection process and prejudice candidates who had supplied accurate information.

The contention that the appellants merely wished to surrender the bonus marks did not alter the position, since deleting the marks would itself require revision of the final merit list.

The Court therefore found no error in the Writ Court’s directions or in the applicable legal reasoning.

Candidates who made incorrect declarations regarding the RCI qualification and failed to use the correction opportunities could not seek post-result deletion of the bonus marks or reopening of the recruitment process.

The Court held that the Writ Court had committed no error in directing verification and revision of the merit list and in refusing to grant further indulgence.

Accordingly, all the writ appeals were dismissed, with no order as to costs; a photocopy of the order was directed to be placed in each connected appeal.