01Facts
On December 15, 2021, the Uttar Pradesh Subordinate Service Selection Commission issued an advertisement for 9,212 posts of Health Workers (Female), reserving 10% (921 posts) for the Economically Weaker Section (EWS) category
p. 2The last date for application was January 5, 2022
p. 2Under Clause 8.3, candidates were required to submit EWS certificates issued by the last date of application in the prescribed proforma
pp. 2-3For this recruitment cycle, a valid certificate needed to relate to the financial year (FY) 2020–2021 and be issued between April 1, 2021, and January 5, 2022
p. 4The appellants submitted certificates that were either issued before the relevant FY concluded (Jan/Feb 2021) or cited the incorrect FY (e.g., 2019-20 or 2021-22)
pp. 5-7Consequently, they were excluded from the EWS merit list despite scoring higher than the last selected candidate
pp. 7-8A Single Judge of the High Court initially directed the State to issue fresh, corrected certificates, but this was overturned by the Division Bench, which held the original certificates invalid
pp. 10-13The appellants then approached the Supreme Court.
02Issues
i.1. Whether the EWS certificates submitted by the appellants, which did not strictly relate to the financial year prior to the year of application or were issued prematurely, could be considered valid for claiming reservation
¶ 18ii.2. Whether the appellants were entitled to relief on the ground that the errors in the certificates were attributable to the issuing State authorities
¶ 11, 2603Law Applied
The Court applied the U.P. Public Services (Reservation for Economically Weaker Sections) Act, 2020, specifically Section 7, which incorporates the Office Memorandum dated 18.02.2019
pp. 14-15This OM stipulates that EWS eligibility is based on family income for the "financial year prior to the year of application"
p. 15The Court relied on the precedent in UPSC v. Gaurav Singh Ors. (2024) 2 SCC 605, which established that a certificate relating to the wrong financial year goes to the root of eligibility
p. 17It further cited Divya v. Union of India (2024) 1 SCC 448, holding that a candidate must possess the requisite Income and Asset Certificate in the prescribed form on or before the cut-off date
p. 18Provisions in the judgment · 1
UTTAR PRADESH PUBLIC SERVICES (RESERVATION FOR ECONOMICALLY WEAKER SECTIONS) ACT, 2020 Section 7
04Reasoning
The Court reasoned that because the advertisement was published in December 2021, the relevant "prior financial year" for income assessment was 2020-2021
p. 4The certificates submitted by most appellants were issued in January or February 2021, meaning they were issued before the relevant financial year (ending March 31, 2021) had even concluded; thus, they could not accurately reflect the total income for that year
p. 12, 16Regarding the appellant whose certificate was issued in 2022, it was invalid because it mistakenly assessed the 2021-2022 FY instead of 2020-2021
p. 17The Court rejected the argument that the State was at fault for issuing incorrect certificates, noting that the appellants had ample time between the advertisement date (15.12.2021) and the cut-off date (05.01.2022) to obtain certificates conforming to the specific requirements of the recruitment notice
pp. 16-1705Holding
The Supreme Court dismissed the appeals, holding that the respondents were justified in rejecting the appellants' EWS claims because they did not possess valid certificates in the prescribed form for the correct financial year by the cut-off date
pp. 18-19The Court emphasized that in large-scale public recruitments processed via automated software, strict adherence to application requirements is necessary to avoid stalling the recruitment process
p. 18No order was made as to costs
p. 19Original Court PDF
Poonam DwivedivsState Of U.P
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