“Strict-Format Rule” for Reservation Certificates in Public Employment:
Supreme Court’s Decision in Mohit Kumar v. State of Uttar Pradesh (2025 INSC 704)

1. Introduction

The Supreme Court of India, in a conjoined civil appeal (Mohit Kumar & connected matter), clarified the legal position concerning the submission of caste certificates for Other Backward Class (OBC) reservation in State recruitment. Two aspirants—Mohit Kumar and Kiran Prajapati—were denied selection as Sub-Inspector/Platoon Commander in the Uttar Pradesh Police because they submitted OBC Non-Creamy Layer certificates in the Central Government format rather than the format mandated by the State’s recruitment notification. Conflicting Allahabad High Court orders prompted the State and the candidates to approach the Supreme Court, presenting a common question: Is the recruiting authority bound to accept an OBC certificate that is indisputably genuine but not in the precise State-prescribed format?

2. Summary of the Judgment

A two-judge Bench (Dipankar Datta & Manmohan, JJ.) held:

• The requirement in Clause 5.4(4) of the recruitment notification—submission of an OBC certificate in Format-I prescribed by the State—is mandatory.
• Failure to furnish the certificate in that format justifies treating the candidate as belonging to the unreserved category, with consequential application of higher cut-off marks.
• The High Court’s order favouring Mohit was upheld (appeal dismissed), whereas the orders favouring Kiran were overturned (appeal allowed); both candidates, therefore, obtained no relief.
• The Court distilled a principle of general applicability: in public employment, once a selection process begins, all aspirants must meet the conditions of the advertisement literally, unless such conditions offend Articles 14/16 of the Constitution.

3. Detailed Analysis

3.1 Precedents Cited and Their Influence

1. Registrar General, Calcutta High Court v. Shrinivas Prasad Shah (2013) 12 SCC 364
   Established that a candidate’s community status must be certified by the competent authority in the prescribed manner. The Court used this case as the lynchpin: if a statutory or formal requirement exists, its breach is fatal.
2. Gaurav Sharma v. State of U.P. (All. FB, 2013)
   Upheld the State’s power to prescribe income criteria for “creamy layer.” Quoted to justify the State-specific format because creamy-layer declarations differ between Centre and States.
3. Bedanga Talukdar v. Saifudaullah Khan (2011) 12 SCC 85
   Reaffirmed that relaxation cannot be granted de hors rules; relied on to refuse equitable indulgence.
4. State of T.N. v. G. Hemalathaa (2020) 19 SCC 430
   Reiterated the supremacy of recruitment-notification terms—cited by State and accepted by the Court.
5. Candidates cited Dolly Chhanda (2005), Ram Kumar Gijroya (2016), Karn Singh Yadav (2024) to seek leniency. The Court distinguished them on facts: those cases involved production of certificates after selection or clerical lapses, whereas here format-specific compliance was a stated eligibility condition.
6. Meeta Sahai v. State of Bihar (2019) 20 SCC 17
   Quoted to explain that participation in a process does not bar a candidate from challenging unconstitutional procedures. The Court, however, found no constitutional infirmity in Clause 5.4(4).

3.2 Legal Reasoning

The Bench’s reasoning is multi-layered:

• Advertisement as “Charter”: Drawing from service-law jurisprudence, the advertisement binds both the candidates and the employer. Once issued, any candidate who ignores its clear terms does so at his own peril.
• Mandatory vs. Directory Requirement: The Court treated Clause 5.4(4) as mandatory, not merely directory, because (a) language used (“will be treated as unreserved”), and (b) the administratively significant objective—verification of “creamy-layer” per State G.O. dated 17-12-2014—which is different from the Central criteria.
• Equality Under Articles 14/16: No violation found. All OBC aspirants faced the same requirement; hence, equal protection and equal opportunity were preserved.
• Doctrine of “Calculated Chance”: Candidates participated without seeking clarification; after being unsuccessful they challenged the rule—disallowed under the doctrine that one who takes a calculated chance cannot later question unfavourable results.
• Precedential Consistency: Though some coordinate Benches dismissed SLPs in similar matters, non-reasoned dismissal orders are not binding precedents (Art. 141 explanation).

3.3 Impact on Future Litigation and Administration

• Administrative Certainty: Recruiting bodies nationwide may now confidently insist on compliance with certificate formats without fear of ex-post judicial dilution.
• Uniformity in Reservation Verification: States can draft bespoke creamy-layer declarations; candidates must procure State-specific certificates. A divergence between Central and State formats is judicially recognised.
• Litigation Filter: The judgment discourages “technical-leniency” petitions and may reduce litigation where non-compliance is purely procedural.
• Policy Re-evaluation: States might revisit certificate formats to include QR codes/digital verification, thereby simplifying, yet not diluting, the mandatory nature.
• Recruitment Timeline: By warning that certificates must be correct ab initio, the decision can shorten post-selection disputes and expedite appointment processes.

4. Complex Concepts Simplified

Creamy Layer

The income/wealth threshold above which a member of an OBC is treated as economically advanced and therefore ineligible for reservation benefits. Each State may notify its own threshold; the Centre maintains a separate one.

Format-I Certificate

A State-specific template containing: (a) caste confirmation, (b) domicile confirmation, (c) 3-year parental income under ₹8 lakh, and (d) declaration of wealth below Wealth-Tax limits. Without all these components, the certificate is non-compliant.

“Calculated Chance” Doctrine

A principle that bars a candidate, who willingly participates in a selection process despite knowing its rules, from later challenging those rules after an unfavourable result.

5. Conclusion

Mohit Kumar v. State of Uttar Pradesh crystallises the “Strict-Format Rule” for reservation certificates in public employment. The Supreme Court reaffirmed that:

1. Recruitment terms are sacrosanct.
2. Compliance with the prescribed certificate format is a substantive, not procedural, requirement.
3. Courts will not intervene merely on equitable grounds when a candidate disregards an unambiguous eligibility condition.

The judgment thus tightens the procedural rigour surrounding affirmative-action benefits, ensures administrative convenience, and sets a binding precedent that will reverberate across future recruitment cycles—both within Uttar Pradesh and in other States with similar dual-format scenarios.