Madhya Pradesh High Court

Mandatory submission of candidate-specific domicile certificates by the cut-off date is an essential eligibility condition.

Yogendra Singh Gurjar v. Airport Authority of India and Others [2026:MPHC-IND:6076]

Madhya Pradesh High CourtJUDGMENT: no citation2 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The Petitioner applied for the post of Junior Assistant (Fire Services) under Advertisement No. DR-01022025WR.

Source reference: para. 2

The 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, 18

The Petitioner, aged 24 at the time of application, uploaded his father’s 2016 domicile certificate instead of his own.

Source reference: para. 3, 20

After clearing the Computer Based Test, the Petitioner presented his own domicile certificate dated 05.01.2026 during document verification.

Source reference: para. 4, 5

The verification committee orally rejected his candidature for failing to produce a valid domicile certificate issued prior to the cut-off date.

Source reference: para. 5

The Petitioner challenged this rejection via a Writ of Certiorari.

Source reference: para. 1
02

Issues

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, 14

2. 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. 16
03

Law 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. 15

Regarding 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, 22

It 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. 21
04

Reasoning

The Court first resolved the jurisdictional challenge, noting the advertisement did not explicitly exclude other courts' jurisdiction.

Source reference: para. 14

On 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. 18

The 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, 21

The personal certificate obtained in 2026 was post-dated and thus invalid for the recruitment cycle.

Source reference: para. 22

The 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, 23

Since the respondents lacked the power to relax these mandatory conditions under the advertisement, the rejection was deemed lawful.

Source reference: para. 24
05

Holding

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. 25

The final holding dismissed the Writ Petition, vacated the previous interim order, and disposed of all pending applications.

Source reference: para. 26, 27
Madhya Pradesh High Court

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Yogendra Singh Gurjar v. Airport Authority of India and Others [2026:MPHC-IND:6076]

Madhya Pradesh High Court · no citation

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