Facts
The Petitioner applied for the post of Junior Assistant (Fire Services) under Advertisement No. DR-01022025WR.
Source reference: para. 2The recruitment mandated candidates to be domiciles of specific states, including Madhya Pradesh, and required uploading a domicile certificate by the cut-off date of 24.03.2025.
Source reference: para. 2, 18The Petitioner, aged 24 at the time of application, uploaded his father’s 2016 domicile certificate instead of his own.
Source reference: para. 3, 20After clearing the Computer Based Test, the Petitioner presented his own domicile certificate dated 05.01.2026 during document verification.
Source reference: para. 4, 5The verification committee orally rejected his candidature for failing to produce a valid domicile certificate issued prior to the cut-off date.
Source reference: para. 5The Petitioner challenged this rejection via a Writ of Certiorari.
Source reference: para. 1Issues
1. Whether the High Court of Madhya Pradesh at Indore has territorial jurisdiction to entertain the petition despite the advertisement stipulating Mumbai as the forum for dispute resolution.
Source reference: para. 9, 142. Whether a candidate can satisfy eligibility criteria by submitting a parent’s domicile certificate or a personal certificate obtained after the prescribed cut-off date.
Source reference: para. 16Law Applied
The Court applied the principle regarding ouster clauses from *A.B.C. Laminart (P) Ltd. v. A.P. Agencies* (1989), holding that unless exclusive words like "alone" or "only" are used, the jurisdiction of other competent courts is not ousted.
Source reference: para. 15Regarding recruitment, the Court emphasized strict adherence to the terms of the advertisement and the mandatory nature of cut-off dates for eligibility.
Source reference: para. 18, 22It further applied the principle that once a person attains majority, they must possess a domicile certificate in their own name for public employment purposes.
Source reference: para. 21Reasoning
The Court first resolved the jurisdictional challenge, noting the advertisement did not explicitly exclude other courts' jurisdiction.
Source reference: para. 14On the merits, the Court found that Clauses 6(ii) and 8(e)(iii) of the advertisement made the cut-off date of 24.03.2025 mandatory for all eligibility criteria.
Source reference: para. 18The Court reasoned that the Petitioner, being 24 years old, could not rely on his father’s certificate issued during his minority.
Source reference: para. 20, 21The personal certificate obtained in 2026 was post-dated and thus invalid for the recruitment cycle.
Source reference: para. 22The Court observed that granting relaxation to the Petitioner would result in "reverse discrimination" against approximately 15 other candidates whose candidatures were rejected on identical grounds.
Source reference: para. 11, 23Since the respondents lacked the power to relax these mandatory conditions under the advertisement, the rejection was deemed lawful.
Source reference: para. 24Holding
The Court answered both issues in the negative regarding the Petitioner’s claims.
It held that the rejection of the Petitioner’s candidature was neither arbitrary nor illegal as he failed to comply with the mandatory documentary requirements by the cut-off date.
Source reference: para. 25The final holding dismissed the Writ Petition, vacated the previous interim order, and disposed of all pending applications.
Source reference: para. 26, 27Original Court PDF
Yogendra Singh Gurjar v. Airport Authority of India and Others [2026:MPHC-IND:6076]
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