CISF Sub-Inspector’s Challenge To Rounded-Off Assistant Commandant Exam Result Dismissed For 2½-Year Delay: Delhi HC

In brief

The question

1. Whether the writ petition challenging the examination result and the petitioner’s non-recommendation was barred by delay and laches.

The court held

The Court held that the petition was barred by delay and laches.

It also directed

The Court dismissed it without adjudicating the substantive challenges to UPSC’s rounding-off procedure or the reduction of one vacancy.

01Facts

The petitioner challenged the final result of the CISF Assistant Commandants (Executive) Limited Departmental Competitive Examination, 2023, declared on 13 March 2024.

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He claimed that his actual aggregate marks of 366.21 exceeded the 366.19 marks of a recommended candidate, but that UPSC’s rounding-off procedure made their scores equal and the age-based tie-breaker placed the other candidate higher.

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He also challenged the reduction of one advertised vacancy.

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The petitioner had represented to UPSC and received its response on 25 April 2024 explaining the rounding-off and tie-break procedures, but filed the writ petition only in October 2026.

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The selected candidates had by then been appointed and were serving.

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02Issues

i.1. Whether the writ petition challenging the examination result and the petitioner’s non-recommendation was barred by delay and laches.

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ii.2. Whether the Court should consider the petitioner’s challenges to UPSC’s rounding-off procedure and the reduction of one vacancy despite the delay.

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03Law Applied

The Court applied the doctrine of delay and laches in the exercise of writ jurisdiction under Article 226 of the Constitution.

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It stated that the doctrine applies with greater force to disputes concerning selections, appointments, promotions and seniority than to claims involving matters such as pay fixation or pension.

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The Court also considered the settled principle that belated challenges to completed selection processes may prejudice the rights of selected candidates.

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No specific statutory provision or precedent was cited for these propositions.

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04Reasoning

The petitioner knew of his non-recommendation when the result was declared in March 2024 and received UPSC’s explanation in April 2024, yet the petition did not explain his inaction for more than two and a half years.

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The Court considered the delay particularly significant because the petition challenged a selection process concluded in 2024 and the successful candidates had already been appointed.

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Allowing the challenge at that stage could adversely affect their rights and have a cascading impact.

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In the absence of any explanation or sufficient cause for the delay, the Court declined to examine the merits of the rounding-off and vacancy challenges.

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