Waitlisted candidate has no indefeasible right to appointment once the prescribed validity of the panel expires.

The Petitioner participated in the recruitment for Junior Stenographer (English) under Respondent No. 1 (DSSSB) via Advertisement No. 02/2012. She qualified all tests and was placed at Rank 12 in the Unreserved (UR) waiting list

The Result Notice dated 13.12.2018 stipulated that the waitlist would remain valid for one year, expiring on 12.12.2019

While Respondent No. 1 nominated additional candidates just after the expiry based on a pre-expiry requisition, Respondent No. 2 (NDMC) made a fresh requisition for two more candidates on 20.05.2021—17 months after the list's expiry

DSSSB refused to forward the Petitioner's dossier, citing the expired validity. The Central Administrative Tribunal (CAT) dismissed the Petitioner's challenge on 19.01.2026

1. Whether a candidate in a waiting list possesses an indefeasible right to appointment after the expiration of the list’s prescribed validity period

2. Whether the issuance of a supplementary result notice shortly after the expiry date constitutes a waiver of the limitation period or an estoppel against the authorities

The Court applied the principle that inclusion in a waiting list does not confer an indefeasible right to appointment, as established in Shankarsan Dash v. Union of India

It further relied on the recent Supreme Court precedent in Rajasthan Public Service Commission, Ajmer v. Yati Jain Ors (2026 INSC 64), which clarifies that a waiting list has a limited validity period and a candidate’s right to be considered does not survive its expiry, especially for vacancies arising after the panel stands exhausted

The court also noted the limits of judicial review under Article 226, emphasizing that the High Court cannot substitute its view for a plausible view taken by a Tribunal unless there is patent illegality

The Court reasoned that the Petitioner’s status was strictly that of a waitlisted candidate whose eligibility was bound by the one-year validity period ending 12.12.2019

It rejected the Petitioner's argument that the Supplementary Result Notice dated 18.12.2019 extended the list, characterizing that notice as a "misnomer" or a "minor irregularity" intended merely to finalize requisitions made prior to the expiry

The Court distinguished between naming candidates for vacancies reported during the life of the list versus those reported 17 months late

Since the requisition for the Petitioner's appointment was made long after the list lapsed, Respondent No. 1 was legally justified in refusing to process the dossier to protect the rights of future aspirants and maintain the integrity of the recruitment cycle

The Court concluded that the Tribunal’s decision was a "plausible view" and did not suffer from perversity or error of law. Consequently, the refusal to sponsor the Petitioner’s name 17 months post-expiry was upheld as valid