Non-possession of essential eligibility qualifications on the prescribed cut-off date disqualifies candidates for public employment.

The 15 appellants applied for graduate and post-graduate teacher positions in Assam following an advertisement dated 26-12-2023

Although they participated in the recruitment examination, they were disqualified for failing to produce B.Ed. degree certificates—an essential eligibility criterion—by the cut-off date of 20-11-2024

The appellants argued that their results were delayed by Babasaheb Ambedkar Education University

They had submitted a representation for relaxation on 11-11-2024 and challenged a corrigendum dated 15-03-2024 which withdrew provisions for relaxing eligibility criteria

A Single Judge dismissed their writ petition (WPC No. 6409/2025) on grounds of delay, laches, and lack of legal right

The appellants preferred this intra-court appeal.

1. Whether the non-declaration of results by a University entitles a candidate to relaxation of a mandatory cut-off date for eligibility in public recruitment

2. Whether the issuance of a corrigendum withdrawing relaxation provisions during the recruitment process constitutes an impermissible "change in the rules of the game"

3. Whether the doctrine of legitimate expectation or equitable sympathy can override notified recruitment criteria

The court applied the principle that recruitment to state services must be based on transparent, objective, and uniform standards, where the cut-off date serves a vital constitutional purpose

It relied on the doctrine that administrative representations do not create enforceable legal rights unless supported by statute or rules

Regarding the "rules of the game," it followed the Constitution Bench principles in Tej Prakash Pathak v. Rajasthan High Court, which allow regulatory or clarifying modifications that do not alter substantive eligibility or comparative merit

It emphasized the principle of estoppel, noting that candidates who participate in a selection process with full knowledge cannot later challenge its conditions (approbate and reprobate doctrine)

The Court reasoned that the B.Ed. degree was an essential qualification that the appellants objectively lacked on the cut-off date; the university's delay did not legally obligate the State to suspend its recruitment timeline

The Court dismissed the "legitimate expectation" argument, holding that past indulgences do not create perpetual rights to future relaxations

Regarding the corrigendum, the Court found it was not a substantive "change in rules" but a clarification ensuring uniform application of existing criteria by removing discretionary relaxation powers

The Court further noted that the appellants’ delay in approaching the court (20 months after the corrigendum) was fatal, as third-party rights had vested in the selected candidates

The Court held that while the State admitted 1,659 posts remained vacant, allowing the appellants entry now would violate the "level playing field" for other similarly situated candidates who did not apply or were rejected for the same lack of qualification

The Court affirmed the Single Judge's decision, ruling that the recruitment process was valid and that no grave illegality warranted judicial interference

The writ appeal was dismissed, with no order as to costs