Expired driving license renders applicant ineligible for driver post; renewal does not backdate validity.

The applicant, Kuljit, sought permission from the Central Administrative Tribunal to participate in the Trade Test for the post of Constable (Driver) (Male) in the Delhi Police Examination, 2022.

The recruitment notification, issued on July 8, 2022, mandated possession of a valid Driving License for Heavy Motor Vehicles (HMV) as of the closing date for online applications, July 29, 2022.

The applicant qualified for the Computer Based Examination and the Physical Endurance & Measurement Test (PE&MT).

However, during verification, it was discovered that the applicant's HMV Driving License, initially issued on May 22, 2018, had expired on May 21, 2021, and was only renewed on September 7, 2022.

Consequently, the applicant was not permitted to appear in the Trade Test because he did not possess a valid HMV license on the crucial date of July 29, 2022.

1. Whether the applicant, who did not possess a valid HMV Driving License as of the closing date of application (July 29, 2022), is entitled to participate in the Trade Test?

The court applied the principle that eligibility of a candidate must be determined with reference to the last date prescribed in the advertisement, and qualifications acquired subsequent thereto cannot be considered, as established in Ashok Kumar Sharma v. Chander Shekhar (1997) 4 SCC 18.

It further relied on the precedent from Bedanga Talukdar v. Saifudaullah Khan (Civil Appeal No. 8344/2011, decided on September 28, 2011), which reiterated that the terms and conditions of an advertisement constitute the law governing the selection process and must be strictly complied with.

Additionally, the court cited Union of India v. Kali Dass Batish (2006) 1 SCC 779, holding that courts cannot relax eligibility conditions prescribed in recruitment rules on sympathetic grounds.

The Apex Court's decision in Telangana State Level Police Recruitment Board Versus Penjarla Vijay Kumar & Ors. Etc. (Civil Appeals No. OF 2025 [@ Special Leave Petitions (Civil) No.8684-8688 Of 2024], decided on December 18, 2025) was also referenced, stipulating that a renewed license after a gap does not backdate its validity to cover the interregnum, and the requirement of continuously possessing a license must be given a literal interpretation.

The court found that the recruitment notification clearly mandated possession of a valid HMV Driving License as of the closing date for receipt of online applications, which was July 29, 2022.

The applicant's HMV license had expired on May 21, 2021, and was renewed only on September 7, 2022.

Therefore, on the crucial date of July 29, 2022, the applicant did not possess a valid HMV Driving License.

The court emphasized that merely applying for renewal does not confer legal validity upon an expired license.

Citing established precedents, the court affirmed that eligibility conditions are mandatory and cannot be relaxed, nor can qualifications acquired after the stipulated date be considered.

The court also referred to the principle that a renewed license does not retroactively validate the period of its expiry, and the requirement of continuous possession must be strictly interpreted.

Given these legal principles, the respondents were justified in denying the applicant's participation in the Trade Test.

The actions of the respondents were found to be in consonance with the recruitment notification and settled principles of law, thus negating any claim of arbitrariness or violation of Articles 14 and 16 of the Constitution.

The Original Application was dismissed, being devoid of merit.

All pending applications, if any, were also disposed of, with no order as to costs.