Submission of Non-Creamy Layer certificate after the cut-off date entails forfeiture of reservation benefits.

The Petitioner applied for the post of Regular Mazdoor (Group-C) under Advertisement No. PHC/01/2025.

The last date for application was 18.03.2025.

Although the Petitioner submitted her caste, residential, and income certificates, she failed to submit an Extremely Backward Class (Non-Creamy Layer) ("NCL") certificate before the cut-off date.

She obtained the NCL certificate only on 06.02.2026, after completing various examination stages.

Consequently, the Respondents treated her as a general category candidate. She was not selected as she did not meet the general category cut-off.

1. Whether the denial of reservation benefits due to the submission of an NCL certificate after the cut-off date is arbitrary or unsustainable in law.

2. Whether the Petitioner's candidature must be considered under the EBC category based on certificates obtained after the recruitment process commenced.

The court applied the principle of strict adherence to the terms and conditions stipulated in the recruitment advertisement.

Specifically, it recognized that where an advertisement explicitly mandates the production of a particular certificate (NCL) to claim reservation and warns that failure to do so results in treatment as a general candidate, those terms are binding.

The Petitioner relied on Ram Kumar Gijroya vs. D.S.S.S.B & Anr. (2016) 4 SCC 754 regarding delayed submission of certificates and Dolly Chhanda vs. Chairman, JEE & Ors. (2005) 9 SCC 779 regarding procedural requirements not defeating substantive rights.

The Court distinguished the Petitioner’s claims from the cited precedents by focusing on the specific, clear language of the recruitment advertisement.

The advertisement explicitly stated that candidates claiming reservation must produce the NCL certificate issued by the competent authority, and failure to do so would result in the candidate being treated as an unreserved/general category candidate.

The Court noted that the Petitioner’s NCL certificate was obtained on 06.02.2026, nearly a year after the application deadline of 18.03.2025 and long after the written test on 22.06.2025.

The Court reasoned that since the terms of the advertisement were explicit regarding the consequences of missing documentation, there was no administrative infirmity in the Respondents' decision to evaluate her under the general category.

The Court held that because the Petitioner failed to provide the NCL certificate by the cut-off date prescribed in the advertisement, the Respondents rightly considered her under the general category.

The writ petition was dismissed, and all pending applications were disposed of.