Gujarat High Court

### Reserved Category Eligibility Requires Possession of Valid Certificate Throughout the Prescribed Document Uploading Window

HIRAL PRAVINKUMAR RAYCHURA vs STATE OF GUJARAT

Gujarat High CourtJUDGMENT: July 09, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner applied for the post of Assistant Director (IT), Class-I under Advertisement No. 108/2024-25 issued by the Gujarat Public Service Commission (GPSC).

Source reference: para. 2.1

At the time of application (February 2025), she held a valid Economically Weaker Section (EWS) certificate dated 08.08.2022, valid until 07.08.2025.

Source reference: para. 2.1

Candidates were required to upload documents between 17.09.2025 and 26.09.2025.

Source reference: para. 2.2

The petitioner’s EWS certificate expired on 07.08.2025, and her renewed certificate was only issued on 04.11.2025.

Source reference: para. 7(iii)

The GPSC treated her as an unreserved category candidate per Instruction No. 7(10) of the advertisement.

Source reference: para. 2.4

Although she attended the interview, she was excluded from the final select list while a candidate with lower marks in the EWS Female category was recommended.

Source reference: para. 2.5–2.6
02

Issues

1. Whether a candidate can claim reservation benefits based on a certificate renewed after the cut-off date prescribed for document verification in the advertisement.

Source reference: para. 8

2. Whether the respondent-GPSC’s action of treating the petitioner as an unreserved category candidate due to the expiration of her EWS certificate during the selection process was legal and valid.

Source reference: para. 9
03

Law Applied

Article 226 of the Constitution of India regarding the High Court's discretionary jurisdiction.

Source reference: para. 1

Principle of strict adherence to the terms and conditions of a recruitment advertisement.

Source reference: para. 8

Clause 9 of the advertisement stipulated that for recruitments involving a preliminary exam followed by scrutiny, the requisite eligibility certificate must be valid as of the last date prescribed for uploading documents.

Source reference: para. 6(ii), 8

Eligibility criteria and cut-off dates are binding and must be applied uniformly to ensure non-discrimination.

Source reference: para. 9
04

Reasoning

The Court analyzed the timeline of the recruitment process against the validity of the petitioner’s EWS certificate; while the petitioner possessed a valid certificate at the initial application stage in February 2025, the Court emphasized that Clause 9 of the advertisement created a specific mandate: the certificate must be valid on the last date of the document-uploading window (26.09.2025).

Source reference: para. 7(ii), 8

Since the petitioner's certificate expired on 07.08.2025 and the renewed certificate was only obtained on 04.11.2025, she lacked a valid document during the critical verification period.

Source reference: para. 7(iii)

The Court reasoned that the language of the advertisement was explicit and left no room for pragmatic or equitable interpretations that would allow a late certificate to "relate back" to the relevant date.

Source reference: para. 8–9

Uniform application of these rules is necessary to maintain the integrity of the selection process.

Source reference: para. 9
05

Holding

The Court dismissed the petition, holding that the petitioner could not claim the benefit of reservation under the EWS category as she failed to provide a valid certificate by the deadline prescribed in the advertisement.

The Court affirmed that the GPSC was justified in treating her as an unreserved candidate; no equitable relief was granted as the terms of the advertisement are binding upon all candidates.

Source reference: para. 6(i), 9
Gujarat High Court

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HIRAL PRAVINKUMAR RAYCHURAvsSTATE OF GUJARAT

Gujarat High Court · July 09, 2026

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