Eligibility for recruitment is determined on the application deadline absent specific rules permitting subsequent qualification acquisition.

The Appellant-RPSC invited applications for 181 posts of Assistant Prosecution Officer via an advertisement dated March 7, 2024, which prescribed a Degree in Law as the essential qualification

The Respondents, who were final-year law students at the time, applied despite not having completed their degrees

RPSC issued press notes on November 19 and 29, 2024, clarifying that candidates must possess the requisite qualification by the last date of application and mandated the withdrawal of ineligible applications

The Respondents, having acquired their degrees by August 22, 2024 (after the application deadline but before the exam), challenged these notices. Both a Single Judge and a Division Bench of the Rajasthan High Court ruled in favor of the candidates, directing RPSC to permit them to sit for the examination

1. Whether the relevant date for acquiring the minimum essential qualification is the date of submission of the application or any time prior to the commencement of the interview/examination process

Rule 12 of the Rajasthan Prosecution Subordinate Service Rules, 1978 prescribes the academic qualifications for the post

While a prior proviso allowed final-year students to apply subject to qualifying before the selection, this proviso was expressly deleted by a notification dated October 10, 2002

The Court applied the legal maxim "aliquid prohibetur ex directo, prohibetur et per obliquum" (what cannot be done directly cannot be permitted to be done indirectly)

The Court observed that the deletion of the proviso to Rule 12 in 2002 evidenced a clear legislative intent: candidates must possess the degree at the time of application

It rejected the High Court’s reasoning that "two interpretations" were possible; the Court held that the advertisement's requirement to "possess" a degree is unambiguous and excludes those who might acquire it in the future

The Court reasoned that moving the eligibility cutoff to the exam or interview stage would create administrative chaos and uncertainty, as eligibility must be assessed based on documents furnished at the time of application

The press note dated November 29, 2024, was deemed a valid clarification of the existing rules, not a mid-process change of conditions

The Supreme Court allowed the appeals and set aside the High Court’s judgment. Consequently, the Respondents, who did not possess Law degrees on the application deadline, were ineligible to participate in the recruitment process