Eligibility for Category-Based Relaxation Depends on Possession of Valid Certificate on the Prescribed Cut-Off Date

The Petitioner challenged the selection and recommendation for the appointment of Respondent No. 3 to the post of ‘Forester’ conducted by the Uttarakhand Subordinate Service Selection Commission (UKSSSC).

The advertisement required male candidates to have a minimum height of 163 cm, relaxable to 152 cm for candidates from specified hill communities, provided they submitted a "hill certificate" with their application.

Respondent No. 3 declared his height as 164 cm in his online application (the deadline for which was 28.02.2025) but did not upload a hill certificate.

During physical measurement, his actual height was found to be 160 cm—below the general standard.

However, the Selecting Body granted him the relaxation benefit because he produced a hill certificate issued on 26.11.2025 during document verification.

The Petitioner sought a writ of certiorari to quash this appointment and a mandamus for the reassessment of vacancies.

1. Whether a candidate is entitled to the benefit of a relaxed standard (height) if the supporting certificate (hill certificate) is obtained and produced after the last date of submission of the application.

2. Whether a petitioner, after participating in a selection process without protest, can challenge the requisition of vacancies sent by the State.

The court applied the principle that eligibility criteria and claims for reservation or relaxation must be satisfied as of the cutoff date specified in the advertisement.

In the absence of a contrary stipulation, a candidate seeking benefit under a special category must possess the requisite certificate on or before the last date of application submission and must present it as prescribed.

The doctrine of estoppel applies to candidates who participate in a selection process unconditionally and subsequently attempt to challenge the underlying requisition or selection criteria after being declared unsuccessful.

The court found that Respondent No. 3 failed to meet the general height requirement of 163 cm, measuring only 160 cm.

His eligibility was contingent upon the "hill candidate" relaxation, which required the submission of a certificate with the application form.

Since the certificate was issued on 26.11.2025, nearly nine months after the application deadline of 28.02.2025, the Selecting Body erred in accepting it.

The court reasoned that eligibility must be determined by the cutoff date to prevent arbitrary inclusions after the process has commenced.

On the second issue, the court held that the Petitioner was estopped from challenging the state's requisition of vacancies because he had already participated in the selection process held strictly according to that requisition.

The recommendation in favor of Respondent No. 3 was set aside.

The court directed that the resulting vacancy be filled by the next meritorious candidate from the appropriate category in the waiting list.

The Petitioner’s prayer regarding the reassessment of the requisition was rejected on the grounds of estoppel.

The writ petition was allowed in part.