Failure to produce mandatory original certificates disentitles candidates from further recruitment stages.

Manikandan applied for appointment to the post of Grade-II Police Constable pursuant to TNUSRB Notification No.2 of 2025 dated 21.08.2025. After clearing the written examination held on 09.11.2025, he was required to produce his original certificates and participate in the Physical Measurement Test/Endurance Test/Physical Efficiency Test scheduled for 28.01.2026.

He produced a photocopy of his 10th Standard mark sheet but not the original, claiming that it had been lost during the Gaja cyclone in 2018; a certificate to that effect had been issued by the Tahsildar, Aranthangi. The Recruitment Sub-Committee rejected his candidature and denied him participation in the physical tests. The learned Single Judge directed the TNUSRB to conduct a separate physical measurement test, consider his candidature, and withhold the result until he produced a certified copy of the mark sheet. The TNUSRB challenged that order in the present writ appeal.

1. Whether the TNUSRB could relax the notification’s mandatory requirement that candidates produce their original certificates before being permitted to participate in the physical tests?

2. Whether the respondent’s explanation that his original 10th Standard mark sheet was lost during the 2018 Gaja cyclone justified permitting him to proceed in the selection process despite non-production of the original certificate at the prescribed stage?

3. Whether the learned Single Judge was justified in directing a separate physical test and conditional consideration of the respondent’s candidature?

The Court applied the principle that the terms and conditions of a recruitment notification, including requirements relating to submission or production of certificates within the prescribed time, are mandatory and binding on all candidates unless the notification itself provides for relaxation.

Relying on State of Tamil Nadu v. G. Hemalatha, 2020 (19) SCC 430, the Court held that recruitment instructions having the force of law must be strictly complied with and that a court exercising jurisdiction under Article 226 cannot modify or relax them.

The Court also relied on B. Lalitha v. Secretary to Government, Tamil Nadu Public Service Commission, W.A. Nos.188 and 901 of 2023, decided on 13.02.2024, which reaffirmed that failure to submit required documents within the prescribed period ordinarily entails rejection and that courts cannot override uniformly applicable recruitment conditions.

The Court further considered the equality principle under Article 14, holding that post-selection relaxation could prejudice candidates who may not have applied had they known that the mandatory condition could later be waived.

The Court found that the notification expressly required production of original certificates and stipulated that candidates who failed to produce them would not be permitted to participate in the physical tests.

Manikandan knew of this requirement when he applied in August 2025 and when he was called for certificate verification in January 2026. Although he asserted that the original mark sheet had been lost in 2018, he had approximately seven years to obtain a duplicate or certified replacement and had not done so before verification.

The Court observed that a duplicate certificate, if produced at the relevant stage, could have been considered by the authorities; however, the respondent had produced only a photocopy when the original was required.

Permitting him to undergo a separate physical test after the prescribed stage would amount to judicial relaxation of a uniform and mandatory recruitment condition, contrary to G. Hemalatha and B. Lalitha, and would undermine equality among candidates under Article 14.

The Division Bench allowed the writ appeal and set aside the learned Single Judge’s order dated 03.02.2026 in W.P.(MD) No.2970 of 2026. There was no order as to costs, and the connected miscellaneous petition was closed.