Reserved Category Candidates Entitled to Cumulative Age Relaxation for Both Category Status and Apprenticeship Training

The petitioner, a B.Sc. graduate and OBC (Non-Creamy Layer) candidate, completed a 24-month Apprenticeship Training as a Boiler Attendant with the respondent, Indian Oil Corporation Ltd. (IOCL).

In 2021, IOCL advertised for the post of Junior Engineering Assistant-IV (P&U). The advertisement provided a 3-year age relaxation for OBC (NCL) candidates (Clause G.3) and a maximum 1-year relaxation for those possessing a Boiler Competency Certificate (Clause G.10).

Although the petitioner secured 93 marks in the written test—significantly higher than the finally selected candidate (73 marks)—his candidature was rejected at the shortlisting stage for being over-aged by 7 months and 6 days.

IOCL initially contended that relaxations could not be combined, but later admitted in an affidavit that the petitioner was erroneously denied the additional one-year relaxation under Clause G.10 due to recruitment irregularities.

1. Whether a candidate belonging to a reserved category (OBC-NCL) is entitled to a cumulative age relaxation by combining the category-based relaxation with the specific qualification-based relaxation (Boiler Competency Certificate) provided in the advertisement.

2. Whether the apprenticeship training period qualifies the candidate for relaxation under the specific terms of the recruitment notification.

U.P. State Road Transport Corporation v. U.P. Parivahan Nigam Shishukhs Berozgar Sangh, which mandates that if service rules are silent, age relaxation should be granted to trainees to the extent of their apprenticeship period.

Judicial consistency as per Gauhati High Court's own precedent in WP(C) No. 1307/2016, which affirmed that reserved category candidates are entitled to additional age relaxation attributable to apprenticeship training over and above their category relaxation.

The interpretation of the advertisement followed the rule of beneficial construction for recruitment notices.

The Court noted that IOCL’s admission of "erroneous denial" and "irregularities" in their supplementary affidavit effectively conceded the legal point that the petitioner was entitled to the one-year relaxation under Clause G.10.

The Court rejected the argument by Respondent No. 5 (the appointed candidate) that Clause G.8 and G.9 barred the relaxation, distinguishing previous case law (WP(C) No. 6253/2021) because the current post (Post Code 202) specifically did not require further experience for B.Sc. candidates with Boiler Apprenticeship.

Since the petitioner secured 93 marks compared to the appointee's 73, the Court reasoned that denying him the opportunity to participate in the Skill/Proficiency/Physical Test (SPPT) based on a flawed age calculation caused a failure of merit-based selection.

The court directed the respondent authorities to consider the petitioner for the SPPT after granting the one-year relaxation under Clause G.10; if the petitioner qualifies the SPPT, he must be considered for appointment based on his superior merit in the written examination within three months.

The court declined to set aside the termination of Respondent No. 5, but affirmed that the petitioner’s higher marks gave him a "better claim" to the post subject to qualifying the SPPT.