Relaxation at Any Stage of the IFS Examination Bars “General Standard” Migration for Unreserved Insider Cadre Allocation
1. Introduction
This decision concerns the interface between (i) relaxed qualifying standards applied to reserved-category candidates at the Preliminary (screening) stage of the Indian Forest Service (“IFS”) selection, and (ii) the later question of whether such candidates may be treated as selected on “general standards” for purposes of cadre allocation, particularly to secure an unreserved “Insider” (home-State) vacancy.
The core dispute arose after the UPSC final merit list (based on Main (Written) + Personality Test) placed the Scheduled Caste candidate G. Kiran (Respondent No. 1) at a higher rank than the general category candidate Antony S Mariyappa (Respondent No. 3). However, Kiran had entered the Main Examination only by clearing the Preliminary Examination using the SC relaxed cut-off.
The Central Administrative Tribunal and the Karnataka High Court answered “yes,” emphasizing that Preliminary marks do not count in final merit. The Supreme Court reversed, holding that relaxation at any stage disqualifies “general standard” treatment for such allocation.
2. Summary of the Judgment
- The Supreme Court allowed the appeals and set aside the Karnataka High Court’s order affirming the Tribunal.
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It upheld the cadre allocation notification allocating:
- Karnataka “General Insider” vacancy to Respondent No. 3 (general category); and
- Tamil Nadu cadre to Respondent No. 1 (SC candidate), as no SC insider post was available in Karnataka.
- The Court held that Respondent No. 1, having used a relaxed cut-off in the Preliminary Examination, was not “selected on general standards” and therefore could not be allocated against an unreserved insider vacancy under the governing Rules and cadre allocation policy.
3. Analysis
3.1 Precedents Cited
The Court’s reasoning is anchored in a consistent line of authority distinguishing (a) reserved candidates who compete on exactly the same standards as general candidates, from (b) those who enter or proceed in the selection process through any relaxation/concession.
(a) Deepa E.V. v. Union Of India and Ors. (2017) 12 SCC 680
The Court treated Deepa E.V. v. Union Of India and Ors. as a foundational statement of the “express bar” principle: where recruitment rules/policy bar migration after availing relaxation (there, age relaxation), the candidate cannot be adjusted against unreserved vacancies. The present Bench extended the logic from age relaxation to qualifying-mark relaxation at the Preliminary stage.
(b) Gaurav Pradhan v. State of Rajasthan (2018) 11 SCC 352
The Court relied on Gaurav Pradhan v. State of Rajasthan to reaffirm:
- Where governing rules/circulars impose an embargo, reserved candidates who took relaxation (e.g., age) cannot migrate to unreserved vacancies.
- Administrative interpretations that allow such migration (displacing unreserved candidates) are impermissible.
This case strengthened the Court’s interpretive stance: once relaxation is used to stay in the selection funnel, later merit cannot cure the fact that the candidate was not competing on identical terms from the outset.
(c) Niravkumar Dilipbhai Makwana v. Gujarat Public Service Commission (2019) 7 SCC 383
Niravkumar Dilipbhai Makwana v. Gujarat Public Service Commission supported two propositions used directly in this judgment:
- Reservation and relaxations are policy instruments within Article 16(4); their scope is determined by the applicable orders/rules.
- A relaxation at an “initial qualifying stage” effectively operates through the process: without it, the candidate would not have reached the later stage. Hence the preliminary/final distinction is “totally misconceived” where the relaxation is a gateway.
The Supreme Court borrowed this “gateway” logic: Respondent No. 1 would have been eliminated at the Preliminary stage under general cut-off, so his later superiority in Main + Interview cannot convert his selection into one “on general standards.”
(d) Union of India v. Sajib Roy (2025) SCC OnLine SC 1943
The Court treated Union of India v. Sajib Roy as the immediate synthesis: migration to unreserved seats depends on whether the governing framework permits it; if an embargo exists, courts cannot override it by invoking general merit notions. Applying that framework here, the Court found an embargo embedded in the text of the Exam Rules, 2013.
(e) Cases relied on by Respondent No. 1, but distinguished
- Jitendra Kumar Singh v. State of UP (2010) 3 SCC 119: distinguished because it turned on Uttar Pradesh instructions expressly permitting migration even after availing certain relaxations. Here, the Exam Rules, 2013 contained the opposite constraint (“any stage of examination”).
- Ajithkumar P. v. Remin K. R. (2015) 16 SCC 778: distinguished because the preliminary examination there lacked statutory basis; here, the Preliminary stage was expressly part of the two-tier statutory scheme (Rule 1).
- Vikas Sankhala And Others v. Vikas Kumar Agarwal And Others (2017) 1 SCC 350: distinguished on the Court’s reading that relaxation in TET pass marks was an eligibility threshold, but did not confer an advantage in the later recruitment scoring—whereas here, Preliminary relaxation was a decisive entry condition into the selection pipeline.
3.2 Legal Reasoning
(i) The statutory architecture: Preliminary is an integral “stage of the examination”
The Court’s interpretive fulcrum is Rule 1 of the Exam Rules, 2013, which defines IFS selection as a two-tier examination: Preliminary screening followed by Main (Written) and Interview. Even if Preliminary marks do not count in final merit, the Preliminary remains a mandatory gateway.
(ii) The “any stage” proviso controls: Rule 14(ii) proviso
The decisive text is the proviso to Rule 14(ii), which contemplates that reserved candidates recommended “without resorting to any relaxations/concessions in eligibility or selection criteria, at any stage of the examination” shall not be adjusted against reserved vacancies—i.e., they are treated as general merit for adjustment purposes. The Court read the converse as inevitable: if a candidate did resort to relaxation at any stage, he cannot claim treatment as selected on general standards for unreserved adjustment.
(iii) Harmonising Rule 14 with the Cadre Allocation Policy (Para 9)
Paragraph 9 of the Cadre Allocation Policy provides that a “reserved category candidate selected on general standards” is eligible for allocation against unreserved vacancies by merit and preference. The High Court equated “general standards” with “general qualifying standard” in Rule 14(i) (the UPSC’s post-interview unreserved qualifying mark).
The Supreme Court rejected this as an unduly narrow reading because it ignores:
- Rule 14(ii) proviso’s explicit “any stage” language; and
- Rule 1’s recognition that Preliminary is a formal tier of the examination.
Therefore, “general standards” for the purpose of Para 9 of the Policy cannot be reduced to only the Main + Interview threshold; it requires absence of relaxation throughout the examination pipeline.
(iv) Screening test argument rejected: non-counting of marks does not erase the stage
Respondent No. 1 argued that because Preliminary marks are not counted in the final merit, the relaxation should be irrelevant to cadre allocation. The Court held the opposite: even if the marks do not count, qualifying at that stage is compulsory; hence relaxation there is still a relaxation “at a stage of the examination.” The Court treated the Preliminary relaxation as causally determinative: absent relaxation, Respondent No. 1 would have been eliminated and never reached the Main + Interview.
(v) Application to facts
- General cut-off in Preliminary: 267; Respondent No. 1 scored 247.18 (below general cut-off).
- He qualified only because SC cut-off was 233.
- Hence, he had “resorted to” relaxed standards at an examination stage; consequently, he could not be treated as selected on “general standards” for allocation to Karnataka’s “General Insider” vacancy.
3.3 Impact
(i) Doctrinal clarity for “migration” in multi-stage competitive exams
The judgment concretely extends the “relaxation bars migration” principle to a common design of Indian competitive exams: where a Preliminary stage is a screening gateway, and only the Main stage determines final merit. The Court clarifies that screening-stage relaxation still counts as relaxation at a “stage of the examination,” with downstream consequences for unreserved adjustment and cadre allocation.
(ii) Cadre allocation disputes: strengthening rule-based predictability
By holding that Para 9 of the cadre allocation policy must be read with Rule 14(ii) proviso, the Court makes cadre allocation less susceptible to “equity-based” rebalancing by adjudicatory bodies that might otherwise prioritise final merit rank alone. This is likely to reduce litigation where reserved-category candidates seek unreserved insider cadres after entering the selection funnel through relaxed screening thresholds.
(iii) Institutional consequences for UPSC/DoPT-style frameworks
Although this case concerns the IFS Exam Rules, 2013 and the MoEFCC cadre allocation, the reasoning aligns with central-government OMs and prior Supreme Court authority. Administrations are incentivised to:
- draft explicit “embargo” clauses if they wish to bar migration after relaxations; and
- ensure recruitment notifications and rules consistently define when a reserved candidate is treated as “general standard.”
(iv) Merit vs substantive equality: the Court’s chosen balance
The respondent’s argument framed denial of the insider general vacancy as anti-merit (given higher final rank) and contrary to Articles 14 and 16. The Court’s response, though not couched as a full constitutional proportionality analysis, effectively treats the rule’s “any stage” condition as a legitimate policy choice within the reservation framework: merit is assessed within the boundaries of the applicable rules defining equal competition.
4. Complex Concepts Simplified
- “Relaxed standard” vs “General standard”: A relaxed standard is any easing of eligibility/selection criteria for reserved categories (here, a lower Preliminary cut-off). A general standard means competing without such easing at every relevant stage, if the rules say “at any stage.”
- “Migration” (reserved to unreserved): When a reserved-category candidate is counted against an unreserved (open) vacancy because they qualify on the same standards as everyone else. This judgment says migration is barred if the candidate used relaxation at any stage where the rules impose such a bar.
- Preliminary as “screening”: Even if its marks do not count in final ranking, it is still a required tier. If you needed relaxation to pass it, you benefited from reservation at a stage the rules treat as legally consequential.
- “General Insider vacancy”: A cadre seat earmarked for an insider/home-state candidate in the general (unreserved) category. Allocation depends on merit, preference, and the policy’s rules on who counts as “general standard.”
5. Conclusion
The Supreme Court in UNION OF INDIA v. G. KIRAN establishes a clear rule for IFS cadre allocation under the Exam Rules, 2013: if a reserved-category candidate avails any relaxation at any stage of the examination—including the Preliminary screening stage—he cannot later be treated as selected on “general standards” for allocation against unreserved vacancies (including an unreserved insider cadre vacancy).
The decision reinforces a rule-based understanding of “merit” in competitive examinations: merit-based migration to unreserved seats is permissible only when the candidate has competed on identical standards throughout the process, where the governing rules so require.
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