The Madhya Pradesh High Court ruled that candidates are solely responsible for regularly checking recruitment websites for updates and deadlines. The Court refused to relax document submission timelines, holding that recruitment advertisements cannot be diluted by judicial intervention.
The Madhya Pradesh High Court has dismissed a petition filed by an assistant professor candidate who failed to submit her document verification papers within the prescribed time limit. The Court clearly held that conditions mentioned in recruitment advertisements for government jobs must be strictly followed and cannot be relaxed by courts.
The matter was heard by Justice Jai Kumar Pillai, who was dealing with a petition filed by a candidate seeking a direction to the Madhya Pradesh Public Service Commission (MPPSC) to accept her verification documents even after the cut-off date had passed.
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While dismissing the plea, the High Court observed,
“It is a settled principle that terms of an advertisement are sacrosanct and cannot be diluted by judicial interpretation.”
The Court emphasised that recruitment advertisements form the foundation of the entire selection process and must be followed strictly by all candidates.
The Court further noted that
“The responsibility to regularly monitor the commission’s website for all information relating to the advertisement, amendments, results, and further instructions is solely upon the candidate.”
It clarified that candidates cannot later claim ignorance of deadlines or procedural requirements once they have chosen to participate in the recruitment process.
The Court also took note of the fact that the commission had clearly stated that it would not entertain individual communications. As recorded in the order,
“The commission has categorically disclaimed any obligation to act upon emails, correspondence, or telephone communications.”
The High Court explained that once a candidate applies for a post, the advertisement itself creates binding conditions. The order stated,
“In effect, the advertisement creates a statutory obligation upon the candidate, and once the petitioner chooses to participate in the selection process with open eyes, she is deemed to have accepted these conditions in toto.”
It was further observed that the consequences of missing deadlines were clearly mentioned in the advertisement. The Court recorded,
“The consequence of non-submission of documents by the stipulated date is clearly spelled out that the candidate shall be deemed unwilling to participate in the interview and their candidature shall stand cancelled, followed by action as per rules.”
In the present case, the Court noted that the petitioner had admittedly failed to submit the required documents within the prescribed timeline. The order highlighted that
“The petitioner admittedly failed to submit her documents within the prescribed time period. Even after extensions were granted with late fees, the petitioner did not comply with the timeline.”
The Court further held that once the final deadline expired, the commission no longer had the authority to entertain the petitioner’s request. As stated in the judgment,
“Once the final date expired, the commission became functus officio in so far as the petitioner’s candidature was concerned.”
The petitioner attempted to justify her delay by citing illness. However, the Court rejected this argument, stating,
“Furthermore, the petitioner has sought to justify her default on the grounds of illness. This Court is unable to accept such a contention for more than one reason.”
The Court explained the reasons for rejecting this claim. Firstly, it pointed out that
“Firstly, the advertisement and the rules with declared result do not contain any clause enabling relaxation of the document verification schedule on medical or personal grounds.”
Secondly, the Court stressed the importance of fairness and equality in public employment, observing,
“Secondly, recruitment to public posts is governed by the principles of certainty, transparency, and equal opportunity.”
The judgment further clarified that allowing relaxation for one candidate would unfairly disadvantage others. The Court stated,
“Granting relaxation to one candidate on personal grounds would necessarily result in discrimination against other candidates who complied with the schedule despite their own difficulties.”
It was also clearly held that courts cannot introduce equity where no legal provision exists. The order said,
“In the absence of a statutory provision, no equity can be imported by judicial fiat.”
The Court also addressed the fact that the petitioner was allowed to attend the interview due to an interim order passed earlier. It clarified,
“The petitioner was permitted to participate in the interview only on account of an interim order passed by this court.”
Importantly, the Court reiterated settled law that participation under interim protection does not create any right. The judgment stated,
“It is well-settled that participation in a selection process under the protection of an interim order does not confer any vested or equitable right upon the candidate.”
After examining all submissions, the Court concluded,
“The court finds no merit in the contention raised by the petitioner in this regard.”
The High Court finally warned against judicial interference in recruitment conditions, stating,
“Any interference at this stage would amount to rewriting or diluting the conditions of the advertisement, which is impermissible in law.”
The case arose from a December 2022 advertisement issued by the MPPSC for the recruitment of assistant professors. The petitioner, who belongs to the Scheduled Tribe (SC) category, cleared the written examination and was included in the provisional merit list. She was required to submit her documents for verification by October 24, 2024.
However, the petitioner failed to submit her documents within the original deadline as well as the extended period provided by the commission. She later submitted a representation on November 25, 2024, claiming that she was suffering from Mixed Connective Tissue Disease (MCTD), which caused the delay. This representation was rejected by the commission.
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Although the High Court, through an interim order dated December 16, 2024, allowed her to appear for the interview subject to the final outcome of the case, the commission later declared the final result in July 2025 and forwarded its recommendations to the state government for issuance of appointment orders.
In light of these facts, the High Court dismissed the petition and upheld the principle that recruitment rules and timelines must be followed strictly to maintain fairness, transparency, and equality in public employment.
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