Selection processes must strictly adhere to advertisement terms regarding the specific authority prescribed for document certification.

The appellant applied for the post of Assistant Professor (History) pursuant to Advertisement No. AP-HIST-08/20-21

Clause 4.1(ii) of the advertisement, in accordance with UGC Regulations 2018, required candidates to submit a five-point Ph.D. certificate duly certified by the Registrar or the Dean (Academic Affairs) of the concerned University

The appellant submitted a certificate signed by the Vice-Chancellor before the cut-off date of 30.12.2020

The Bihar State University Service Commission ("Commission") rejected his candidature on 14.10.2024, citing that the certificate was not issued by the competent authority (Registrar/Dean) as prescribed

The appellant subsequently obtained and submitted a certificate signed by the Registrar after the rejection, but the Commission refused to entertain it

The learned Single Judge dismissed the appellant’s writ petition, leading to this intra-court appeal

1. Whether the Commission’s rejection of the appellant’s candidature was valid due to the submission of a Ph.D. certificate signed by the Vice-Chancellor instead of the Registrar/Dean as specified in the advertisement.

2. Whether a candidate can be permitted to submit a rectified eligibility certificate after the prescribed cut-off date mentioned in the advertisement.

The court applied the UGC Regulations dated 18.07.2018, which mandate that Ph.D. compliance must be certified by the Registrar or Dean

It relied on the Full Bench decision in Braj Kishore Prasad v. State of Bihar (1998), which established that documents received after the advertisement's closing date must be rejected unless a public notice for extension is issued

The court further followed the Supreme Court precedent in Bedanga Talukdar v. Saifudaullah Khan (2011), holding that selection processes must strictly adhere to the procedure stipulated in the advertisement, and no relaxation of terms is permissible unless expressly reserved and publicized

The Court observed that Clause 4.1(ii) of the advertisement explicitly incorporated the UGC 2018 requirement that the five-point Ph.D. certificate must be signed by the Registrar or Dean

The appellant’s submission of a certificate signed by the Vice-Chancellor was a deviation from these mandatory terms

Applying the ratio of Bedanga Talukdar, the Court reasoned that the Commission cannot relax the terms of the advertisement for an individual candidate, as doing so would violate the mandate of equality under Articles 14 and 16

Regarding the delayed submission of the correct certificate, the Court noted that the selection process is sacrosanct and governed by the cut-off dates; entertaining documents submitted post-rejection would undermine the integrity of the process

The Court distinguished the appellant’s reliance on Anuradha Singh v. BSUSC, noting that in that case, the selection process had not yet commenced, whereas here, the rules were applied uniformly to all candidates without exception

Since the appellant failed to submit the requisite certificate from the competent authority before the cut-off date, the rejection of his candidature was legal and not arbitrary

The Court found no perversity in the Single Judge’s judgment and dismissed the Letters Patent Appeal