Failure to upload Form-1 cannot defeat eligibility where the original is produced at verification.

The applicants were sportspersons in powerlifting who had won gold medals in international competitions in 2016 and possessed Form-1 certificates issued by the Indian Powerlifting Federation on 12 June 2016 and 30 December 2016, respectively.

Pursuant to the Department of Posts’ recruitment notification dated 8 November 2023 for meritorious sportspersons under the MSP quota, Applicant Priya applied for the post of Postal Assistant and Applicant Ilayabharathi applied for the post of Multi-Tasking Staff. Both were provisionally selected and called for document verification on 22 January 2024. During verification, it was found that, instead of uploading the Form-1 certificate, the applicants had uploaded a Certificate of Honour issued by the Federation. Although they produced the original Form-1 certificates at verification, the certificates were not accepted and their candidature was rejected in the verification statement. Their representations dated 23 January 2024 were not acted upon, leading to the present OAs.

1. Whether the applicants’ candidature could be rejected for uploading a Certificate of Honour instead of the prescribed Form-1 certificate, despite production of the original Form-1 certificate at document verification.

2. Whether the requirement to upload the Form-1 certificate with the online application was mandatory in circumstances where the applicants were otherwise eligible and had produced the original certificate during verification.

3. Whether the applicants were entitled to consideration for appointment under the MSP quota after the rejection of the verification statement.

The Tribunal applied the Department of Personnel and Training instructions dated 3 October 2013 and 8 November 2023, along with the recruitment notification dated 8 November 2023, under which eligible sportspersons were required to possess the prescribed Form-1/2/3/4/5 certificate issued by the competent authority and candidates in the provisional merit list were required to produce the original documents at verification.

The Tribunal relied on Neeraj Sharma v. Union of India & Anr., where an inadvertent upload of an incorrect document, without any intention to gain an advantage or mislead the authorities, was held insufficient to defeat an otherwise valid candidature. It also relied on Tamil Nadu Public Service Commission v. U. Kaviyarasan and the principles from Charles K. Sakaria v. C. Mathew, Dolly Chhanda v. Chairman, JEE and Dhirendra Singh Paliwal, holding that once substantive eligibility is established, furnishing proof is generally procedural and should not defeat candidature on technical grounds.

Although paragraph 12(d) of the notification stated that applications lacking prescribed documents would be rejected, paragraph 15 specifically required candidates in the provisional merit list to produce Form-1 in original at the verification stage.

The Tribunal found that both applicants had timely applied, satisfied the age, educational and meritorious-sportsperson requirements, and participated in a recognised sport qualifying for MSP recruitment. Their uploaded Certificates of Honour disclosed the relevant international powerlifting achievements and did not confer any undue advantage or falsely establish eligibility. Since the applicants had already been included in the provisional select list, the respondents had effectively accepted them for further consideration; if paragraph 12(d) required outright rejection for non-uploading of Form-1, the applications should have been rejected at that stage rather than after provisional selection. The original Form-1 certificates were available, had been issued by the competent authority, and were produced during verification. Accordingly, refusing to consider them elevated a procedural defect in uploading the document over the applicants’ established substantive eligibility.

The respondents were directed to consider the Form-1 certificates dated 12 June 2016 and 30 December 2016 and to consider the applicants for appointment to the posts of Postal Assistant/Multi-Tasking Staff, or any other posts in the cadres for which they had applied under the MSP quota, and to issue appointment orders if they were otherwise eligible. Both OAs were disposed of without an order as to costs.