Submission of Qualification Documents at Any Stage Valid: MP High Court Overturns Appointment Process in Anganwadi Assistant Case"

“Possession of Qualifications at the Time of Application Sufficient; Proof Can Follow” – Madhya Pradesh High Court delivered a landmark judgment addressing procedural fairness in recruitment processes. Justice Pranay Verma held that a candidate’s failure to attach qualification documents with an application does not invalidate their eligibility if proof is submitted before the finalization of the selection process. The Court directed the petitioner’s appointment as Anganwadi Assistant, setting aside orders favoring another candidate.
The case revolved around a recruitment process for the post of Anganwadi Assistant at the Devlabihar Center, Tehsil Gulana, District Shajapur. The petitioner, Smt. Kalabai, had applied for the post along with several others, including the respondent (selected candidate). A provisional merit list placed her at Rank 4, while the respondent was listed as Rank 1.
The petitioner objected, asserting that her Class V marks sheet, which entitled her to additional marks, had been submitted. However, the authorities rejected her claims, stating the marks sheet was not attached to her initial application and thus could not be considered. The petitioner’s appeals to the Collector and Additional Commissioner were similarly dismissed, prompting her to file this writ petition.
The primary issue was whether the petitioner’s Class V marks sheet, submitted with her objection to the provisional merit list, could be considered in determining her final merit position. The Court relied on precedent, particularly the Supreme Court’s ruling in Dolly Chhanda v. Chairman, JEE (2005) and Division Bench decisions in Smt. Mamta Shrivastava v. Women & Child Development Department (2022), which affirm that possession of requisite qualifications at the time of application suffices, even if proof is submitted later.
Justice Verma emphasized that the process of selection remains dynamic until the final merit list is published. The Court rejected the respondents’ reliance on guidelines barring the consideration of documents submitted after the application stage, observing that these guidelines lacked legal binding force and conflicted with judicial principles established by higher courts.
The Court highlighted that the petitioner’s marks sheet demonstrated a score of 66%, qualifying her for an additional 13 marks under the recruitment rules. Consequently, her total score should have been 73, surpassing the respondent’s 67. The denial of these marks, the Court ruled, was unjust and procedurally flawed.
Justice Verma set aside the orders of the Additional Commissioner, the Collector, and the Project Officer, holding that they failed to account for the petitioner’s valid qualifications. The Court directed the authorities to rectify the merit list, place the petitioner at Rank 1, and appoint her as Anganwadi Assistant. The respondent’s appointment was ordered to be annulled within two months.
"The mandatory condition is possession of the minimum qualification as on the date of application. Proof thereof can be submitted at any stage prior to the finalization of the merit list. Denying the petitioner her rightful marks for Class V qualifications, despite her possession of the same, violates principles of fairness and equity."
This judgment underscores the importance of procedural fairness in recruitment processes, affirming that eligibility should hinge on substantive qualifications rather than technicalities of document submission. The decision reaffirms the judiciary’s role in rectifying arbitrary administrative actions that undermine merit-based selection.
Date of Decision: November 12, 2024