Facts
The Bihar Public Service Commission (BPSC) issued Advertisement No. 65/2020 on 30.09.2020 for the post of Assistant Curator, setting a cut-off date of 30.10.2020 for educational qualifications
Source reference: para. 3, 17The petitioner possessed a Master’s degree (2011) but obtained her PG Diploma in Archaeology & Museology on 03.01.2022
Source reference: para. 3, 6Following litigation by another candidate, the BPSC issued a first corrigendum on 30.12.2022 amending qualifications and allowing an "Edit option" for existing applicants
Source reference: para. 10, 20A second corrigendum on 07.12.2023 reallocated seats for ST and BC (Female) categories and explicitly stated that certificates for amended qualifications must be issued on or before 19.12.2023
Source reference: para. 11, 24The petitioner was declared successful in the written test but was later marked "Ineligible" on 22.08.2024 on the grounds that her diploma was obtained after the original 2020 cut-off date
Source reference: para. 9Issues
1. Whether the cut-off date of 19.12.2023 for educational qualifications stipulated in the second corrigendum applied uniformly to all candidates or was restricted only to specific reserved categories
Source reference: para. 252. Whether the BPSC was justified in disqualifying the petitioner for possessing a diploma obtained after 30.10.2020 despite the subsequent corrigenda
Source reference: para. 26Law Applied
The Court examined the Bihar State Archaeology & Museum Service Rules, 2014, regarding essential qualifications
Source reference: para. 12It considered the principles governing cut-off dates in public recruitment as established in Ashok Kumar Sonkar v. Union of India (2007) and Divya v. Union of India (2024), which generally hold that qualifications must be acquired by the date specified in the advertisement or rules
Source reference: para. 14However, the Court applied the principle of administrative consistency and non-discrimination under Article 14, implying that a revised cut-off date introduced via a corrigendum for a modified selection process must apply to all similarly situated candidates
Source reference: para. 25Reasoning
The BPSC argued that the 2023 cut-off date (19.12.2023) applied only to NEW applicants from the ST and BC (Female) categories, while the original 2020 date applied to others
Source reference: para. 14, 25The Court rejected this interpretation, reasoning that the BPSC cannot maintain two different cut-off dates—30.10.2020 for Unreserved/SC/EWS and 19.12.2023 for ST/BC (Female)—for the same recruitment process
Source reference: para. 25Since the first corrigendum allowed all previous applicants to "edit" their qualifications to meet the new criteria, and the second corrigendum explicitly extended the certificate issuance deadline to 19.12.2023, the petitioner was entitled to the benefit of the later date
Source reference: para. 21, 25As her diploma was dated 03.01.2022, it fell well within the revised 2023 deadline
Source reference: para. 26Holding
The Court held that the BPSC erred in disqualifying the petitioner based on the original 2020 cut-off date
The list of ineligible candidates dated 22.08.2024 was quashed specifically regarding the petitioner
Source reference: para. 28The Court directed the BPSC to allow the petitioner to appear for the interview scheduled for 14.03.2026 and to consider her for selection alongside other successful candidates
Source reference: para. 29The writ application was allowed
Source reference: para. 30Original Court PDF
Sudha Singh v. The Bihar Public Service Commission & Ors. [Civil Writ Jurisdiction Case No. 16895 of 2024]
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