EWS Certificates Must Relate To Correct Financial Year; Courts Should Not Routinely Interfere In Online Recruitment Rejections: Supreme Court

"When certificate is sought in respect of a particular financial year, certificate of a different financial year goes to the root of the eligibility of a candidate," Supreme Court, in a significant ruling, held that candidates claiming Economically Weaker Section (EWS) reservation must possess a valid income and asset certificate relating strictly to the financial year prior to the year of application. While upholding the rejection of several candidates for the post of Health Worker in Uttar Pradesh, a bench of Justices Manoj Misra and Prasanna B. Varale observed that submitting a certificate of a different financial year completely invalidates a candidate's eligibility.

The Uttar Pradesh Subordinate Service Selection Commission issued an advertisement in December 2021 to fill 9212 posts of Health Worker (Female), with 921 posts reserved for the EWS category. The appellants submitted EWS certificates that were either issued prior to the closure of the relevant financial year or related to an entirely different financial year. Their candidatures were rejected by the Commission due to these defects, a decision which was initially overturned by a Single Judge of the Allahabad High Court but subsequently restored by the Division Bench. The appellants subsequently approached the Supreme Court.

The primary question before the court was whether EWS certificates issued prior to the closure of the relevant financial year, or denoting an incorrect financial year, could be considered valid for claiming reservation benefits. The court was also called upon to determine the scope of judicial interference in the administrative rejection of defective online applications during large-scale public recruitments.

Strict Adherence To Financial Year Requirement

The court meticulously analyzed the timeline of the recruitment process, noting that the advertisement was issued on December 15, 2021, and the last date for submitting applications was January 5, 2022. The bench clarified that an EWS certificate submitted for this specific recruitment had to relate to the financial year 2020-2021. The judges noted that to be valid, the certificate had to be dated between April 1, 2021, and the application cut-off date of January 5, 2022.

Defective Certificates Invalidate Candidature

Examining the individual documents submitted by the appellants, the court found glaring errors on the face of the certificates. Most candidates had obtained their certificates in January or February 2021, meaning they were issued even before the financial year 2020-2021 had concluded. The bench held that since these certificates were not in respect of the full financial year prior to the application year, the authorities were completely justified in rejecting the claims.

Statutory And Procedural Mandates

The court rooted its reasoning in Section 7 of the Uttar Pradesh Public Services (Reservation for Economically Weaker Sections) Act, 2020, and the corresponding Office Memorandum dated February 18, 2019. The bench observed that the statutory framework strictly requires the assessment of family income for the financial year prior to the year of application. The prescribed Form-I explicitly mandates the disclosure of the specific financial year for which the certificate is valid, leaving no room for ambiguity.

Candidates Cannot Blame The State For Early Issuance

Addressing the appellants' argument that the State authorities were at fault for issuing certificates before the financial year closed, the court found the submission devoid of substance. The judges noted that these certificates were obtained months before the advertisement was even published. The court emphasized that the candidates had ample opportunity to apply for fresh, compliant certificates after the publication of the advertisement but failed to take the necessary steps.

Reliance On Established Precedents

Fortifying its stance, the bench relied upon the Supreme Court's prior decision in UPSC v. Gaurav Singh, noting that documentation errors of this nature are fatal to a candidate's claim. The bench also cited the landmark judgment in Divya v. Union of India, reaffirming the settled legal position that a candidate must possess the requisite income and asset certificate in the prescribed form on or before the cut-off date to claim the benefit of reservation.

"Challenge to such a rejection must not ordinarily be entertained as it could stall expeditious completion of the recruitment process thereby frustrating thousands and lacs of aspirants."

Courts Must Avoid Stalling Public Recruitments

Before concluding the judgment, the bench made crucial observations regarding judicial interference in modern recruitment processes. The court noted that in large-scale public recruitments, online applications and scanned documents are processed through automated computer software. The judges observed that any error in the application form or uploaded documents is bound to result in the automatic rejection of the candidature, and courts should be highly reluctant to interfere in such administrative outcomes.

The Supreme Court ultimately dismissed the appeals, finding no merit in the candidates' claims regarding their defective EWS certificates. The bench upheld the judgment of the Division Bench of the High Court, confirming that the rejections by the Commission were legally sound and necessary to maintain the integrity of the recruitment process.

Date of Decision: 10 April 2026