Reservation Cannot Be Applied to Single Post Cadres as it Amounts to Unconstitutional Total Exclusion

The Directorate of Urban Administration and Development, Chhattisgarh, issued an advertisement on 12.02.2018 to fill 103 posts of Accountant across various Nagar Panchayats and Municipal Councils

The petitioner, a member of the Scheduled Caste category, appeared for the examination and secured 72.449 marks but was not considered for appointment

The petitioner challenged the recruitment process, alleging that the respondent authorities failed to provide reservations for backward classes as per the prevailing state reservation rules

The respondents contended that while 103 posts were advertised in total, each urban local body had only one sanctioned vacancy, making it a "single post cadre" where reservation cannot be applied

1. Whether the respondent authorities were required to apply reservation rules to a recruitment process where each individual local body consisted of only a single sanctioned post

2. Whether a candidate, after participating in a recruitment process with full knowledge of its terms and being declared unsuccessful, can subsequently challenge the validity of the advertisement

The Court primarily applied the principle that reservation cannot be applied to a single post cadre, as it would result in 100% reservation and violate Articles 14 and 16 of the Constitution of India, as established by the Supreme Court in Dr. Chakradhar Paswan v. State of Bihar (1988)

Post Graduate Institute of Medical Education Research, Chandigarh v. Faculty Association (1998)

the court applied the doctrine of estoppel as articulated in Anupal Singh v. State of Uttar Pradesh (2020), which dictates that an unsuccessful candidate who consciously participated in a selection process is precluded from challenging the fairness or legality of that process after the result is declared

The Court found that although 103 total vacancies were advertised, they were distributed such that only one sanctioned post of Accountant existed in each distinct urban local body

Consequently, applying the 12%, 32%, or 14% reservation ratios mandated by the Chhattisgarh Lok Seva (Amended) Rules, 2011, was mathematically impossible for a single vacancy without creating a total exclusion of general category candidates

The Court reasoned that a solitary post cannot be reserved via a roster system as it effectively creates a monopoly for reserved categories in that specific cadre

Additionally, the Court noted that the petitioner participated in the examination knowing the terms of the advertisement and only raised the grievance regarding the lack of reservation after failing to secure an appointment

Following established precedents, the Court held that the petitioner could not "turn around" and challenge the process simply because the outcome was not "palatable" to him

The Court found no merit in the petitioner's challenge to the advertisement dated 12.02.2018

Accordingly, the writ petition was dismissed