ICMR project-service age relaxation requires entry into the project within the prescribed age limit.

The applicant, a Scheduled Caste candidate born on 25 February 1988, applied for a Technical Assistant post advertised by NIRT.

The notification set an upper age limit of 30 years, relaxable by five years for SC/ST candidates, and provided a further project-service relaxation for candidates continuously working in ICMR-funded projects, subject to their having entered project service within the prescribed age limit.

The applicant’s ICMR-funded fellowship proposal was technically approved in March 2022, but he joined the project as a Research Associate on 1 March 2023, after turning 35.

He took the recruitment examination, was provisionally selected and attended document verification.

The respondents rejected his request for project-service age relaxation because he had joined the project after the age ceiling; the rejection was also considered by a Grievance Committee.

He challenged that decision under Section 19 of the Administrative Tribunals Act, 1985, seeking age relaxation and appointment.

Whether the applicant qualified for project-service age relaxation when he joined the ICMR-funded project after exceeding the prescribed upper age limit, notwithstanding the earlier technical approval of his fellowship proposal.

Whether the Tribunal could direct an individual or one-time age relaxation on the ground of administrative delay and the applicant being only three days over the applicable limit.

Section 19 of the Administrative Tribunals Act, 1985 provides the procedural basis for the application.

Rule 12 of the ICMR Technical Cadre Integrated Recruitment and Assessment Rules provides that a person continuously working in ICMR projects may receive age relaxation of up to five years only if they entered project service within the prescribed age limit for the post; the recruitment notification imposed the same condition.

The Tribunal relied on Union of India v. Shivbachan Rai [(2001) 9 SCC 356], recognising that prescribing age limits and the extent of relaxation are matters of policy.

N.S. Siva Kumar v. Addl. Chief Secretary to Govt. of Tamil Nadu [(2020) 2 CTC 241], holding that delay in recruitment does not by itself justify further age relaxation and that selection does not create a right to appointment.

Bedanga Talukdar v. Saifudaullah Khan [(2011) 12 SCC 85] and Ankita Thakur v. H.P. Staff Selection Commission (Civil Appeal No. 7602 of 2023), which state that relaxation must be authorised by the applicable rules or advertisement and cannot be introduced contrary to their terms.

The Tribunal also relied on the limits of judicial review over executive policy stated in Mallikarjuna Rao v. State of A.P. [(1990) 2 SCC 707] and Asif Hameed v. State of Jammu & Kashmir [1989 Supp (2) SCC 364].

The applicant’s SC relaxation extended the ordinary age limit to 35, but he had already attained that age before joining the ICMR project on 1 March 2023.

The earlier technical approval of his fellowship proposal did not alter the fact that he entered project service after the applicable age limit; the governing rule and notification expressly required entry into project service within that limit.

The Tribunal therefore found the respondents’ application of the eligibility condition consistent with the recruitment terms.

It held that administrative delay and the small extent of the excess could not justify rewriting the criteria or granting an individual relaxation, which could also prejudice similarly situated candidates who had not applied because they considered themselves age-barred.

It found no infirmity in the respondents’ decision and dismissed the Original Application, along with any pending miscellaneous applications, with no order as to costs.