Disability candidates are entitled to the same evaluation relaxations as SC/ST candidates in service placement policies.

The Petitioners, Persons with Benchmark Disabilities (PwD), were recruited as Probationary Officers (PO) by the State Bank of India (SBI) in 2018

Under SBI’s policy circular dated April 23, 2019, a continuous assessment of 1000 marks determined two outcomes: (i) confirmation in JMGS-I (standard: 50%, relaxed to 45% for SC/ST and PwD), and (ii) direct placement in the higher MMGS-II grade upon confirmation (standard: 75%, relaxed to 70% for SC/ST candidates only)

The Petitioners scored between 723 and 747 marks—crossing the 70% threshold but falling short of the 75% general requirement

Consequently, they were confirmed in JMGS-I but denied fitment in MMGS-II, whereas SC/ST candidates with identical scores were granted the higher grade

The Petitioners challenged this exclusion as discriminatory during the pendency of which they were eventually promoted to MMGS-II in the regular course

1. Whether the Court has territorial jurisdiction and if the challenge is barred by delay or acquiescence

2. Whether SBI could lawfully grant a 5% relaxation to SC/ST candidates for MMGS-II placement while denying the same to PwD candidates within the same assessment framework

3. Whether Article 335 of the Constitution or Government instructions prohibit extending such relaxation to PwD candidates

The Court applied Article 14 of the Constitution (Right to Equality), which prohibits arbitrary classification and requires a rational nexus between the classification and its object

Rights of Persons with Disabilities (RPwD) Act, 2016, emphasizing the mandate for equal opportunity and removal of barriers in service

The Court followed the precedents of Anamol Bhandari v. Delhi Technological University and Aryan Raj v. Chandigarh Administration, which establish that PwD candidates are entitled to the same relaxed standards as SC/ST candidates in academic and qualifying evaluations unless a rational basis for differentiation is shown.

It further referenced State of Kerala v. Leesamma Joseph to affirm that disability rights extend to career progression, not just entry-level recruitment

The Court rejected SBI’s jurisdictional and delay objections, noting that a material part of the cause of action arose in Delhi where the Petitioners served and were denied benefits

On merits, the Court found that the MMGS-II "fitment" was an incentive-based placement embedded in the confirmation process, not a regular promotion

The Court determined that SBI’s internal records showed an initial intent to include PwD in the relaxation, which was later excluded without a reasoned basis

The Court held that SBI’s reliance on Article 335 was misplaced, as that Article is an enabling provision for SC/ST and do stop the State from extending similar benefits to PwD to ensure Article 14 compliance

Since SBI accepted a 5% relaxation for PwD at the confirmation stage (JMGS-I), it could not provide a rational explanation for treating them as "General" candidates for the MMGS-II placement arising from the same 1000-mark assessment

The Petitioners’ subsequent promotions proved their suitability, highlighting that the initial denial was based on an unequal benchmark rather than merit

The Court ordered SBI to: (i) treat Petitioners as eligible for MMGS-II placement from the original 2021 date; (ii) refix their seniority and pay notionally from that date; (iii) pay differential monetary benefits between the notional date and actual promotion date within twelve weeks; and (iv) permit Petitioners to participate in the MMGS-III promotional exercise based on the refixed seniority, with benefits effective from the 2024-25 promotion year