Facts
The petitioner, a resident of Mumbai, Maharashtra, applied for the post of Constable/GD in the CAPF, SSF, and Assam Rifles Examination, 2024
Source reference: para. 2His candidature was rejected during the Document Verification (DV) stage on October 7, 2024, at the CISF Unit RCFL Mumbai
Source reference: para. 6(03)Although the petitioner qualified in the physical tests (PST/PET), he failed to produce a valid OBC Caste Certificate from his state of domicile (Maharashtra), instead providing one from Uttar Pradesh
Source reference: para. 6(03)Additionally, he incorrectly marked "No" in the online application regarding migration from his state of origin to another state
Source reference: para. 6(05)Despite a seven-day extension granted by the Recruitment Board to produce the correct certificate, the petitioner failed to do so
Source reference: para. 6(08-09)The petitioner challenged the rejection in the Delhi High Court, citing that the initial recruitment notification was issued by the SSC in New Delhi
Source reference: para. 4Issues
1. Whether the Delhi High Court is the forum conveniens to entertain the petition given that the rejection and document verification occurred in Mumbai
Source reference: para. 4, 62. Whether the petitioner’s failure to correctly declare his migration status and provide a domicile-state OBC certificate as per the examination notification justifies the rejection of his candidature
Source reference: para. 6(04-09)3. Whether the petition is liable to be dismissed on grounds of delay, considering a subsequent recruitment cycle for 2025 had already commenced
Source reference: para. 5Law Applied
Staff Selection Commission (SSC) notification dated November 24, 2023, specifically Para 6 (6.2) and Para 20 (5), which mandate that candidates migrating between states must make an informed choice regarding reservation benefits at the time of application
Source reference: para. 6(04)CRPF Directorate’s guidelines dated September 12, 2024, which state that any variation between the District/State mentioned in the application and the Domicile Certificate results in rejection
Source reference: para. 6(06)The court also invoked the principle of forum non conveniens regarding territorial jurisdiction
Source reference: para. 6Reasoning
The Court observed that while the recruitment notification was issued from Delhi, the entire cause of action—including the document verification, the rejection, and the communication of the reply to the legal notice—took place in Mumbai, Maharashtra
Source reference: para. 6the Court found that the petitioner violated the mandatory instructions of the SSC notification by failing to disclose his migration status in Column 21.1 of the application form
Source reference: para. 6(05)The rules clearly stipulate that if a candidate seeks reservation benefits in a migrated state, they must produce a valid certificate from that specific state or be treated as an unreserved candidate
Source reference: para. 6(06)Since the petitioner was given an opportunity under the principles of natural justice to rectify the document deficiency and failed to do so within the stipulated time, the rejection was deemed procedurally and legally sound
Source reference: para. 6(08-09)the Court noted that the 2024 recruitment process was effectively over and the 2025 cycle had begun, making the intervention untimely
Source reference: para. 5Holding
The Court held that there was no merit in the petitioner’s challenge.
It ruled that the mere issuance of a pan-India notification from Delhi does not grant territorial jurisdiction when the material cause of action arose elsewhere
Source reference: para. 6The Court affirmed that the petitioner's failure to adhere to the explicit documentation and application requirements justified the rejection of his candidature
Source reference: para. 7The petition and all pending applications were dismissed
Source reference: para. 7Original Court PDF
Chauhan Anil BholavsUnion Of India & Ors.
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