The Delhi High Court ruled that OBC-Non-Creamy Layer certificates must be accepted if issued at any time within the same financial year. It held that mid-year cut-off dates unfairly deprive candidates of their Article 16 rights.
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NEW DELHI: In a judgment impacting thousands of aspirants across India, the Delhi High Court has ruled that recruitment authorities cannot impose rigid or arbitrary cut-off dates for the issuance of Other Backward Class–Non Creamy Layer (OBC-NCL) certificates.
The ruling came in a case in which the Court held that an OBC-NCL certificate must be accepted as valid so long as it is issued within the same financial year (FY) as the examination for which the candidate applies.
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OBC-NCL status is crucial for candidates seeking reservation benefits in government examinations. Until now, agencies like UPSC imposed narrow windows, sometimes lasting only a few weeks, within which candidates were required to obtain fresh OBC-NCL certificates.
The Court found such rules arbitrary, irrational, and unconstitutional, especially since:
- Caste/OBC status is by birth, and
- The certificate merely evidences income status based on the preceding three financial years.
A Division Bench of Justice C Hari Shankar and Justice Om Prakash Shukla emphasized that income-based OBC-NCL categorization naturally aligns with the financial year, not with arbitrary dates set by recruitment authorities.
The Court observed that,
“The cut-off date in the middle of the FY deprives the petitioners of rights owed to them under Article 16 of the Constitution … The OBC-NCL certificate shall be considered … so long as its date of issuance falls within the same FY as that of the examination.”
The judges concluded that restrictive cut-off windows, like April 1 to May 16, 2023, and April 1 to May 14, 2024, imposed in the CAPF (AC) exams, have no rational nexus with the objective of reservation.
Many candidates who cleared the written examination for CAPF (Assistant Commandant) in 2023 and 2024 saw their candidature:
- Cancelled,
- Converted to the General category, or
- Kept provisional,
because their certificates were not issued within the narrow windows dictated by Rule 21.2 of the CAPF (AC) Examination Rules.
The Court struck down this rule, calling it arbitrary and unconstitutional, and directed the government to reconsider the candidature of all affected aspirants.
Rule 21.2 required:
- Income for the previous three financial years, and
- Certificate issuance only after the latest FY and before the application deadline.
The Court held this to be irrational because income data already corresponds to financial years, and restricting issuance windows unfairly harms candidates entitled to reservation.
The Bench stated:
“Such insistence cannot be allowed to override rights owed to the petitioners under Article 16 of the Constitution of India.”
Appearance:
For the petitioner: Advocates Saaket Jain, Shivangi Anand, Sarthak Kumar Meena, Parth Taran Singh, Saurav Agrawal, Asav Rajan, Ajay Sharma, Mayank Biyani, Akash Saxena, Devang Shrotriya and Kashish Chadha, Pankaj Mehta, Shweta Soni, Akansha Singh and Apaar Puri
For the UPSC: Senior Advocate Naresh Kaushik with Ravinder Agarwal, Manish Kumar Singh and Vasu Agarwal
For the Union of India: Advocates Rajesh Gogna, Priya Singh, Rebina Rai, Shivam Tiwari, Mahamaya Chatterjee, Akash Dubey, Vijendra Singh Mahndiyan, Syed Abdul Haseeb, Wahid Mashaal, Anisul Haque, Akash Vajpai, Archana Kumari, Mukul Singh and Aryan Dhaka
Case Title:
Raghvendra Singh & Anr v Union Public Service Commission & Anr
W.P.(C) 8304/2025, CM APPL. 36115/2025
READ JUDGMENT
