Courts should not disturb an OBC appointment repeatedly verified absent perversity, mala fides, or statutory violation.

The Municipal Corporation of Delhi (“MCD”) advertised the post of Assistant Education Officer (General), for which the selection process was conducted by the Union Public Service Commission (“UPSC”). The UPSC recommended six candidates, including Respondent No. 3, but not the Appellant.

The MCD issued Respondent No. 3 a provisional offer of appointment under the Other Backward Class (“OBC”) quota, subject to verification of her credentials. Her character and antecedents, OBC certificate, and domicile certificate were verified by the Delhi Police, the MCD Vigilance Department, and the Sub-Divisional Magistrate. No adverse material was found.

Various complaints alleged that Respondent No. 3 had fraudulently obtained her OBC certificate. These complaints were investigated and closed after verification.

The Appellant subsequently filed a writ petition challenging Respondent No. 3’s appointment and continuance in service, alleging that she and her family were permanent residents of Haryana, belonged to the Jat community, and that her educational qualifications had been obtained in Haryana, where the community was allegedly not entitled to OBC reservation.

The learned Single Judge dismissed the writ petition, holding that the certificate had been repeatedly verified and that no perversity, mala fide, or statutory violation had been demonstrated. The Appellant preferred the present Letters Patent Appeal.

Whether the Appellant established that Respondent No. 3’s appointment under the OBC quota was based on a fraudulently or unlawfully obtained OBC certificate?

Whether the Appellant had the requisite locus standi to challenge Respondent No. 3’s appointment, despite not being a UPSC-recommended candidate or a person pursuing the matter in public interest?

Whether the learned Single Judge was justified in declining judicial interference with the administrative determination after repeated verification of Respondent No. 3’s credentials?

The Court applied the principles governing judicial review of administrative decisions, namely that interference is justified only where the decision-making process is vitiated by perversity, mala fide, or violation of statutory provisions.

It further applied the principle that a challenge to a public appointment, including one framed as a writ of quo warranto, must be supported by credible material showing that the office-holder lacks legal authority to hold the post; a person who is neither an affected candidate nor genuinely pursuing a public-interest challenge may lack the requisite locus.

The Court also relied on the administrative principle that official certificates and eligibility claims, once verified by competent authorities through proper inquiries, are not to be displaced on the basis of conjectures or unsubstantiated allegations.

The Court found that the allegation of fraud was unsupported by cogent material and rested on conjectures.

Respondent No. 3’s OBC and domicile certificates had been verified by the competent Sub-Divisional Magistrate, while her character, antecedents, and police record had also been examined by the Delhi Police and the MCD Vigilance Department. Subsequent complaints were independently investigated and closed, with no foul play attributable to her being found.

In these circumstances, the Appellant failed to demonstrate perversity, mala fide, or breach of any statutory provision in the decision-making process.

The Court additionally held that the Appellant lacked sufficient locus because he had not been recommended by the UPSC, had not shown a personal legal injury, and had not pursued the matter before the authorities as a public-interest complainant.

Accordingly, there was no basis to disturb the factual determination reached after repeated verification.

The learned Single Judge had correctly declined to interfere with the administrative findings supported by repeated verification processes.

The Letters Patent Appeal was dismissed, with no order as to costs.