Facts
The applicant, a person with a 40% "Specific Learning Disability" (SLD), applied for the Civil Services Examination (CSE) 2025 under Notice No. 05/2025-CSP.
Source reference: p. 2While the applicant was allowed compensatory time during the Preliminary and Mains exams, the notification did not provide for reservation for the SLD category under Section 34(1)(d) of the RPwD Act, 2016.
Source reference: p. 5-6The applicant challenged the exclusion, arguing it was discriminatory as other technical services (Engineering, Medical) provide such reservation.
Source reference: p. 7-8The respondents (DoPT/UPSC) maintained that an Expert Committee had recommended the exclusion of category (d) disabilities for the CSE cycles of 2024–2027 based on functional requirements, a decision concurred with by the DEPwD.
Source reference: p. 16-17During the pendency of the OA, the CSE 2025 results were declared; the applicant scored 648 in the Mains, which was above the PwBD-5 cutoff but below the General category cutoff.
Source reference: p. 24-25Issues
1. Whether the exclusion of "Specific Learning Disability" (SLD) from the reserved categories in the CSE 2025 notification violates the mandatory provisions of the RPwD Act, 2016.
Source reference: p. 7 / para. 42. Whether the Tribunal should interfere with the executive's policy decision regarding functional classification and physical requirements for All India Services.
Source reference: p. 11 / para. 53. Whether the OA survives or has become infructuous following the completion of the CSE 2025 selection process.
Source reference: p. 35 / para. 14Law Applied
Sections 33 and 34 of the Rights of Persons with Disabilities (RPwD) Act, 2016, which mandate a 4% reservation for benchmark disabilities but allow the government to exempt specific establishments based on the type of work.
Source reference: p. 26-27The principle of Stare Decisis and judicial discipline as established in S.I. Rooplal v. Lt. Governor and Sant Lal Gupta v. Modern Coop. G.H. Society Ltd., requiring coordinate benches to follow settled precedents.
Source reference: p. 32, p. 34The executive's domain in policy-making as held in Mallikarjuna Rao v. State of Andhra Pradesh and Union of India v. M. Selvakumar.
Source reference: p. 12Reasoning
The Tribunal observed that the respondents followed the statutory "due process" by constituting an Expert Committee to review functional requirements and obtaining the necessary concurrence from the DEPwD for the exemptions.
Source reference: p. 27-28The Tribunal noted that the Principal Bench (CAT, New Delhi) had already dealt with an identical challenge in Molshree Aggrawal v. Union of India (OA 3553/2024), where it directed a High-Powered Committee to reconsider the exclusion for future exams (CSE 2026 onwards) rather than quashing the existing 2025 process.
Source reference: p. 29-31Applying the rules of judicial decorum from S.I. Rooplal, the Bangalore Bench determined it must align with the Principal Bench's view.
Source reference: p. 32-35Furthermore, since the CSE 2025 process was entirely concluded and results were declared, the specific relief sought by the applicant for that year could no longer be granted.
Source reference: p. 35Holding
The Tribunal held that because the CSE 2025 selection process was completed and the results were officially declared, the application had become infructuous.
The Original Application and all associated MAs were dismissed without costs.
Source reference: p. 36Original Court PDF
SATHWICK SvsDEPARTMENT OF PERSONNEL AND TRAINING
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