Reserved Candidate Availing Relaxed Standards in Prelims Cannot Migrate to General Quota for Cadre Allocation: Supreme Court

“If a reserved category candidate takes benefit of relaxation though at initial stage, it will effectively amount to taking relaxation even at the final stage of the selection process because without giving relaxation to him, he was not in a position to participate in the Main examination.” — In a seminal ruling, the Supreme Court of India, comprising Justice J.K. Maheshwari and Justice Vijay Bishnoi, has set aside a Karnataka High Court judgment, holding that a Scheduled Caste (SC) candidate who qualified the Preliminary Examination using relaxed standards cannot claim a ‘General Insider’ vacancy for cadre allocation, even if they outscored General candidates in the Main Examination.

The Controversy: Merit vs. Qualifying Standards

The dispute arose from the Indian Forest Service (IFS) Examination, 2013. The Respondent No. 1 (G. Kiran), an SC candidate, secured 247.18 marks in the Preliminary Examination. The cut-off for General Category candidates was 267, while for SC candidates it was 233. Thus, G. Kiran qualified for the Main Examination solely by availing the relaxed standard applicable to SC candidates.

However, in the Main Examination and Personality Test, G. Kiran performed exceptionally well, securing Rank 19, surpassing Respondent No. 3 (Antony S Mariyappa), a General Category candidate who secured Rank 37.

The conflict crystallized during Cadre Allocation. There was only one ‘General Insider’ vacancy for Karnataka. The Union of India allocated this to the General candidate (Rank 37) because the SC candidate (Rank 19) had availed relaxation in the Prelims. The Central Administrative Tribunal (CAT) and subsequently the Karnataka High Court ruled in favor of the SC candidate, reasoning that the Preliminary exam was merely a "screening test" and did not count towards final merit.

“The candidate obtaining minimum qualifying marks in Main Examination may be summoned for Interview for personality test... The proviso confers discretion upon UPSC for applying the ‘Relaxed Standards’ to the candidates belonging to the SC, ST and OBC.”

The Supreme Court’s Analysis: The "Integral Stage" Doctrine

The Supreme Court rejected the High Court's view that the Preliminary Examination's "screening" nature rendered the relaxation irrelevant for final allocation. The Bench emphasized Rule 14 of the IFS Exam Rules, 2013, specifically the proviso which states that reserved candidates recommended without resorting to any relaxation or concession in eligibility or selection criteria “at any stage of the examination” shall not be adjusted against reserved vacancies.

The Court held that the Preliminary Examination is an integral stage of the selection process. Since G. Kiran would have been eliminated at the Preliminary stage had he been judged by "General Standards" (267 marks vs. his 247.18), he could not subsequently claim to be a "General Merit" candidate for the purpose of Cadre Allocation.

Interpretation of "General Standards" in Cadre Policy

The Bench scrutinized Paragraph 9 of the Cadre Allocation Policy, which allows a reserved candidate to be allocated against an unreserved vacancy only if selected on "General Standards."

The Court clarified that "General Standards" implies meeting the qualifying criteria of the unreserved category at every stage, including the Preliminary Examination. The Court observed that allowing a candidate who used a "ladder" of relaxation to enter the Main Examination to subsequently claim a General vacancy would violate the level playing field.

“Respondent No. 1, having availed the benefit of ‘Relaxed Standard’ in the Preliminary Examination, cannot be treated as a candidate selected on ‘General Standard’.”

The Court relied heavily on its earlier decisions in Deepa E.V. v. Union of India and Gaurav Pradhan v. State of Rajasthan, reiterating the principle that once a candidate avails a relaxation (age, fees, or cut-off marks) at any stage, they are counted against their respective reserved category.

The Bench distinguished the present case from Jitendra Kumar Singh, noting that in that case, specific state instructions allowed migration despite relaxation, which was absent in the IFS Rules.

The Supreme Court allowed the appeals filed by the Union of India and the General candidate. It restored the original notification dated March 13, 2015, confirming the allocation of the Karnataka Cadre to the General candidate (Antony S Mariyappa) and the Tamil Nadu Cadre to the SC candidate (G. Kiran).

Date of Decision: January 6, 2026