Introduction

In the landmark case of Divya Petitioner(s) v. Union Of India And Others (s). (2023 INSC 900), the Supreme Court of India addressed critical questions surrounding the eligibility criteria for the Economically Weaker Section (EWS) category in the Civil Services Examination (CSE) 2022. The petitioners, having secured commendable ranks, challenged the Union Public Service Commission's (UPSC) decision to deny them EWS reservations based on procedural lapses in certificate submission amid the COVID-19 pandemic.

The central issue revolved around whether UPSC was justified in enforcing strict adherence to the prescribed rules, which included the timely submission of Income and Asset Certificates (I&AC) for EWS eligibility, especially under unprecedented pandemic conditions.

Summary of the Judgment

The Supreme Court dismissed the writ petitions filed by the petitioners, affirming the UPSC's decision to revoke their EWS reservation claims. The court held that the rules stipulated in the Office Memoranda dated 19.01.2019 and 31.01.2019, along with the Civil Services Examination Rules, 2022, were clear and mandatory. The petitioners' inability to present the required I&AC before the designated cut-off date did not warrant exceptional treatment, even considering the hardships posed by the COVID-19 pandemic. Consequently, the court upheld the decisions of UPSC, emphasizing the non-negotiable nature of administrative protocols in competitive examinations.

Analysis

Precedents Cited

The judgment extensively referenced several key precedents to bolster its stance on procedural adherence:

• Charles K. Skaria v. Dr. C. Mathew (1980 SCC 752): Emphasized the importance of adhering to prescribed dates for eligibility qualifications.
• Dolly Chhanda v. Chairman, JEE (2005 SCC 779): Reinforced that lack of proper documentation could nullify eligibility, even if the candidate qualified otherwise.
• Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board (2016 4 SCC 754): Addressed the necessity of possessing correct financial year documentation for EWS eligibility.
• Ashok Kumar Sharma v. Chander Shekhar (1997 4 SCC 18): Highlighted that eligibility deadlines are binding and cannot be relaxed without undermining the selection process.
• Dheerender Singh Paliwal v. Union Public Service Commission (2017 11 SCC 276): Stressed that procedural rigidness ensures fairness and prevents arbitrary selection.
• Deepak Yadav v. Union Public Service Commission (2021 709): Discussed exceptions during extraordinary circumstances like the COVID-19 pandemic but clarified that such exceptions are not universally applicable.

Legal Reasoning

The Supreme Court meticulously dissected the procedural framework governing the EWS reservation in CSE-2022:

• Eligibility Criteria: Under Rule 27(3) and Rule 28 of the CSE-2022 Rules, candidates must meet the Central Government's criteria and possess the requisite I&AC based on the Financial Year (FY) 2020-2021 by the cut-off date of 22.02.2022.
• Mandatory Compliance: Rule 13 mandates the timely submission of Detailed Application Forms (DAF-I) along with supporting documents, failing which candidature is canceled.
• No Scope for Relaxation: The court held that allowing selective relaxation of rules would compromise the integrity of the examination process and lead to administrative chaos.
• Estoppel Argument Rejected: Petitioners' claims that UPSC waived certain rules through communications were dismissed, reinforcing that rules are procedural and must be uniformly applied.
• Consistent Judgment: The court emphasized consistency with prior rulings, dismissing arguments that sought to reinterpret or override established precedents.

Impact

The judgment sets a stringent precedent for future examinations and reservations:

• Strict Adherence to Rules: Institutions must ensure that all eligibility criteria and procedural deadlines are unequivocally communicated and enforced.
• Limited Flexibility: Even in circumstances like pandemics, exceptions to procedural norms are rare and must be justified with compelling evidence.
• Uniform Application: The ruling underscores the necessity for uniform application of rules to maintain fairness and transparency in competitive examinations.
• Legal Clarity: Clarifies that administrative rules framed under executive power hold enforceable legal status, thereby preventing arbitrary interpretations.

Complex Concepts Simplified

Economically Weaker Section (EWS)

The EWS category is a reservation scheme in India aimed at providing opportunities to candidates from economically disadvantaged backgrounds. Eligibility is determined based on specific income and asset criteria, ensuring that reservations reach those genuinely in need.

Income and Asset Certificate (I&AC)

The I&AC is an official document verifying a candidate's financial status. For EWS eligibility, the certificate must reflect the candidate's income and assets for a specified financial year, as mandated by government regulations.

Civil Services Examination Rules, 2022

These are the official guidelines governing the conduct of the Civil Services Examination in 2022. They lay down the procedures for application, eligibility, reservation policies, and other critical aspects to ensure a fair and transparent selection process.

Unnamed Precedents

Refers to court cases cited in the judgment that have established legal principles relevant to the current case but may not be widely known.

Conclusion

The Supreme Court's decision in Divya Petitioner(s) v. Union Of India And Others reinforces the sanctity of procedural rules in competitive examinations. By upholding UPSC's stringent eligibility criteria for the EWS category, the court emphasized that rules are designed to ensure fairness, equality, and integrity in the selection process. This judgment serves as a crucial reminder that administrative guidelines must be followed meticulously, and exceptions are permissible only under extraordinary circumstances with substantial justification. Future candidates and examination bodies must take heed of this ruling to maintain the robustness and credibility of competitive examinations in India.