OBC Applicant’s 2026 Disability Certificate Alone Didn’t Establish PwD Eligibility By 2022 Cut-Off: CAT

In brief

The question

1. Whether the applicant, relying on a disability certificate issued on 19 October 2026, could claim consideration under the PwD category in a recruitment process initiated under the 2022 advertisement.

The court held

The Tribunal declined to grant the reliefs sought and dismissed the O.A.

It also directed

Pending miscellaneous applications, if any, were disposed of, with no order as to costs.

01Facts

The applicant applied under the OBC category for the post of Physical Education Teacher (Post Code 41/22), advertised on 14 October 2022.

¶ 2–2.1

After a public notice dated 17 September 2026 provided an opportunity for PwD candidates to apply, he obtained a disability certificate on 19 October 2026. He sought to be considered under both OBC and PwD categories, but the online portal did not permit him to add the PwD category to his existing application. He challenged the notice insofar as it prescribed 18 November 2022 as the cut-off date for the PwD certificate, and sought consideration under the PwD quota.

¶ 2–2.1

The respondents opposed the application, relying on the notified recruitment conditions and eligibility criteria.

¶ 3

02Issues

i.1. Whether the applicant, relying on a disability certificate issued on 19 October 2026, could claim consideration under the PwD category in a recruitment process initiated under the 2022 advertisement.

¶ 5.1

ii.2. Whether the subsequent opportunity for PwD candidates entitled the applicant to alter or add a reservation category after applying under the OBC category, contrary to the prescribed recruitment terms.

¶ 5.3

03Law Applied

The Tribunal cited no statute, regulation, or judicial precedent. Its reasoning proceeded on the basis that candidature must be assessed according to the applicable recruitment requirements and prescribed cut-off date; a disability certificate issued later does not, by itself, establish that the candidate met the requirements for PwD consideration as of the relevant date.

¶ 3, 5.2–5.3

Nor does a later opportunity to apply under the PwD category, without a provision permitting category changes, automatically confer a right to alter or add a reservation category.

¶ 3, 5.2–5.3

04Reasoning

The Tribunal noted that the applicant had initially applied under the OBC category and that his disability certificate was issued only in October 2026. It held that the later-issued certificate did not establish that he fulfilled the applicable PwD requirements on the relevant date.

¶ 5.2–5.3

Further, the subsequent opening of the portal for PwD candidates did not, absent a provision allowing it, give him a right to add or change his category. The applicant therefore failed to establish a basis for interference with the notice or for the requested consideration under the PwD quota.

¶ 5.2–5.3