### Meritorious Candidate Cannot Be Disqualified for Clerical/Typographical Errors in EWS Certificate Committed by Issuing Authority Summary of the Judgment: The High Court of Bombay set aside an order of the Maharashtra Administrative Tribunal (MAT) which had upheld the MPSC’s decision to exclude a candidate from the merit list due to a date error in her Economically Weaker Section (EWS) certificate. The petitioner, a highly meritorious candidate (scoring 545.75 marks against a category cutoff of 532.25), submitted an EWS certificate dated May 9, 2024. Although it correctly reflected her income for the 2023-2024 financial year, the Tahsildar erroneously labeled it as "valid for 2024-2025." The MPSC disqualified her, arguing she lacked a valid certificate for the recruitment year (2023-2024). Key Legal Principles & Observations: 1. Substance Over Form: The Court held that the MPSC focused excessively on the "form" rather than the "substance" of the certificate. Since the certificate was in the prescribed format and the issuing authority (Tahsildar) later clarified that the date was a typographical error, the eligibility criteria were deemed satisfied. 2. State Error Doctrine: A candidate cannot be made to suffer for a "patent error" or "inadvertent mistake" committed by a government official (the Tahsildar) when the underlying facts (income level) qualify the candidate for the benefit. 3. Distinguishing Strict Compliance: While acknowledging Supreme Court precedents (e.g., *Divya v. UPSC*) regarding strict deadlines and formats, the Court distinguished them by noting that the petitioner *did* possess the status and the document within the timeline; the issue was merely a clerical error by the State rather than a failure of the candidate to acquire eligibility. 4. Absence of Cut-off for Submission: The Court noted that the advertisement did not prescribe a rigid cut-off date for "possession" of the certificate, stating it should be produced during document verification. Conclusion: The Court directed the MPSC to include the petitioner in the select list at the appropriate rank, emphasizing that technicalities should not defeat the rights of a meritorious candidate when eligibility is factually established.

The Petitioner, an Economically Weaker Section (EWS) candidate, applied for the Maharashtra Civil Services under an EWS (Female) category advertisement dated December 29, 2023.

She scored 545.75 marks, exceeding the cut-off of 532.25.

During document verification, the Respondent (MPSC) noted that her EWS certificate, dated May 9, 2024, mentioned validity for "2024-2025," whereas the requirement was for "2023-2024."

Although the certificate reflected a family income of Rs. 7,84,500 for the year 2023-2024 (meeting the threshold), MPSC excluded her from the merit list on technical grounds.

The Tahsildar subsequently issued a clarification on November 7, 2025, stating the year "2024-2025" was a clerical error and the certificate was intended for "2023-2024."

The Maharashtra Administrative Tribunal (Tribunal) dismissed her application on January 29, 2026, holding that MPSC was not required to perform inferential scrutiny.

Whether the Petitioner’s EWS certificate should be deemed valid for the recruitment year 2023-2024 despite a clerical error in the validity period mentioned by the issuing authority.

Whether a meritorious candidate can be disqualified due to a technical error committed by a government officer (Tahsildar) when the substantive eligibility is met.

The Court considered Government Resolutions (GR) dated February 12, 2019, and May 31, 2021, regarding EWS certification requirements.

It evaluated the principles from *Mohit Kumar v. State of Uttar Pradesh* (2025), which dictates that non-compliance with advertisement formats triggers rejection.

It evaluated the principles from *Divya v. Union of India* (2024) regarding the strictness of cut-off dates for possession of certificates.

It evaluated the principles from *Bedanga Talukdar v. Saifudaullah Khan* (2011), which prohibits relaxation of recruitment terms unless specifically reserved.

The Court distinguished the cited precedents by noting that the Petitioner was not non-compliant with the *format* of the certificate, but rather a victim of a clerical error by the Tahsildar.

Unlike *Divya*, the advertisement here did not stipulate a strict cut-off date for submission, and MPSC had even permitted the Petitioner to submit clarifications until November 11, 2025.

The Court found that the certificate dated May 9, 2024, explicitly listed the income for the 2023-2024 period as being below the limit, making the "2024-2025" validity period an "apparent error" on the face of the record.

The Court reasoned that MPSC focused on the "form" rather than the "substance" of the document.

It held that a candidate cannot be made to suffer for a mistake committed by a competent authority (the Tahsildar) when the underlying eligibility (income status) was factually correct and clarified before the final selection.

It held that the Petitioner’s EWS certificate is valid for the year 2023-2024.

The High Court directed MPSC to include the Petitioner’s name at the appropriate place in the select list for the post of Deputy Superintendent of Police / Assistant Commissioner, Group ‘A’, ensuring her merit is recognized.

Relief was granted in terms of prayers (a) and (b) of the Original Application.