Valid EWS reservation requires possession of certificates for the specified financial year by the recruitment cut-off date.

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

The last date for application was January 5, 2022

Under Clause 8.3, candidates were required to submit EWS certificates issued by the last date of application in the prescribed proforma

For 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

The 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)

Consequently, they were excluded from the EWS merit list despite scoring higher than the last selected candidate

A 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

The appellants then approached the Supreme Court.

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

2. Whether the appellants were entitled to relief on the ground that the errors in the certificates were attributable to the issuing State authorities

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

This OM stipulates that EWS eligibility is based on family income for the "financial year prior to the year of application"

The 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

It 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

The Court reasoned that because the advertisement was published in December 2021, the relevant "prior financial year" for income assessment was 2020-2021

The 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

Regarding the appellant whose certificate was issued in 2022, it was invalid because it mistakenly assessed the 2021-2022 FY instead of 2020-2021

The 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

The 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

No order was made as to costs