Madras High Court
Administrative and Public LawConstitutional Law

TNPSC cannot insist on a fresh PSTM certificate where the submitted certificate is in the prescribed format.

D.SARAVANA SUNDAR vs THE TAMIL NADU PUBLIC SERVICE COMMISSION

Madras High CourtJUDGMENT: August 31, 20262 MIN READSOURCE JUDGMENT
TNPSC cannot insist on a fresh PSTM certificate where the submitted certificate is in the prescribed format.. D.SARAVANA SUNDAR vs THE TAMIL NADU PUBLIC SERVICE COMMISSION. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner challenged, under Article 226 of the Constitution, the TNPSC Memorandum No. 1461/OTD-B2/2020 dated 25 August 2026, seeking its quashing and a direction to consider his candidature on the basis of the PSTM certificates already submitted by him.

Source reference: p.1

The petitioner contended that, despite having uploaded a PSTM certificate in the prescribed format in 2024, the Commission was requiring him to produce a fresh certificate.

Source reference: para.3

TNPSC clarified that it had not sought a fresh certificate, but only the certificate in the prescribed format; it further stated that the certificate annexed at page 60 of the petitioner’s typed set appeared to be in the prescribed format, subject to scrutiny.

Source reference: para.4

The petitioner also stated that he had sent the original certificates to the Commission by post and produced the postal receipt, although TNPSC could not confirm their receipt or availability.

Source reference: para.5
02

Issues

1. Whether TNPSC’s communication dated 25 August 2026 unlawfully required the petitioner to produce a fresh PSTM certificate despite his alleged submission of a certificate in the prescribed format.

Source reference: paras.3–4

2. Whether the petitioner’s candidature could be considered on the basis of the PSTM certificate already submitted, subject to verification and scrutiny by TNPSC.

Source reference: paras.4–6

3. Whether the original certificates allegedly sent to TNPSC should be returned to the petitioner if they were available with the Commission.

Source reference: para.6
03

Law Applied

The petition was considered under the constitutional jurisdiction of the High Court under Article 226, including the power to issue certiorari and mandamus.

Source reference: p.1

The applicable administrative principle was that a candidate must furnish the required certificate in the prescribed format, while the recruiting authority is entitled to scrutinise and verify the certificate before proceeding with selection.

Source reference: para.4

No specific statutory provision or judicial precedent was cited or relied upon in the order; the Court principally acted on the clarification and undertaking made by TNPSC before it.

Source reference: paras.4–6
04

Reasoning

The Court found that the dispute arose from a misunderstanding: the petitioner believed that TNPSC was demanding a fresh PSTM certificate, whereas TNPSC clarified that it required only a certificate in the prescribed format.

Source reference: paras.3–4

Since the certificate produced in the typed set appeared to conform to the prescribed format, TNPSC agreed to scrutinise it and proceed with the selection process accordingly.

Source reference: para.4

The Court also noted that the petitioner had been permitted to participate in the interview.

Source reference: para.4

As to the originals allegedly sent by post, TNPSC could not confirm their receipt but undertook to return them if they were available with the Commission.

Source reference: para.5

On recording these submissions, the Court considered no further adjudication necessary.

Source reference: para.6
05

Holding

The writ petition was disposed of by recording TNPSC’s submission that it had not demanded a fresh PSTM certificate and would scrutinise the certificate appearing to be in the prescribed format before proceeding with the selection.

If the petitioner approached TNPSC and the original documents were available with the Commission, TNPSC was directed to return them to him.

Source reference: para.6

No costs were awarded, and the connected miscellaneous petition was closed.

Source reference: para.6
Madras High Court

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D.SARAVANA SUNDARvsTHE TAMIL NADU PUBLIC SERVICE COMMISSION

Madras High Court · August 31, 2026

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