Madhya Pradesh High Court Upholds Recruitment Sanctity, Dismisses Aspirant's Plea Over Late Document Submission
The Madhya Pradesh High Court has delivered a significant ruling, dismissing a plea from a scheduled tribe aspirant who sought consideration for an Assistant Professor position despite missing multiple deadlines for document submission. Justice Jai Kumar Pillai, presiding over the case, emphasized that granting individual relaxations based on sympathetic grounds would set an unhealthy precedent and undermine the integrity of public employment processes.
Case Background and Petitioner's Claims
The petitioner, who had qualified the State Eligibility Test (SET-2022), submitted her online application for the post of Assistant Professor (Botany) in April 2024. She subsequently appeared in the written examination conducted in June 2024 and was placed in the provisional merit list when results were declared in October 2024. The results included clear instructions for submitting required documents within a prescribed timeline, which was extended twice with provisions for late fees.
Despite these extensions, the petitioner failed to submit her documents within any of the specified periods. She later submitted a representation in November 2024, citing ill health as the reason for her inability to meet deadlines. Specifically, she claimed to be suffering from Mixed Connective Tissue Disease (MCTD), which she argued prevented her from checking results and submitting documents on time.
Court's Findings and Legal Reasoning
Justice Pillai's ruling established several crucial legal principles regarding public recruitment:
- Candidate Responsibility: The court affirmed that the responsibility to regularly monitor the recruiting commission's website for all information, including amendments and deadlines, rests solely with the candidate.
- Non-Flexible Deadlines: The judgment clarified that cut-off dates in recruitment processes are not flexible, discretionary, or subject to individual hardship considerations.
- Medical Grounds Insufficient: The court found that medical incapacity, in the absence of specific enabling provisions for relaxation within the recruitment rules or advertisement, cannot serve as a legally sustainable ground to override mandatory conditions.
- Process Finality: The selection process for the Assistant Professor position had already been concluded and finalized in July 2025. The court emphasized that once a selection process attains finality, it should not be disturbed at a belated stage.
Key Arguments Presented
Advocate Prasanna R Bhatnagar, representing the petitioner, argued that his client was fully qualified and had successfully cleared the written examination, thereby deserving consideration for appointment. He contended that the delay was neither deliberate nor intentional, attributing it entirely to her medical condition. Bhatnagar further noted that since the commission had extended deadlines multiple times with late fees, the cut-off date should not be treated as rigid or mandatory.
In response, Advocate Vindhyavashini Prasad Khare, representing the recruiting commission, maintained that the selection process was strictly governed by the terms and conditions outlined in the advertisement and subsequent instructions. Khare highlighted that the October 4, 2024 result explicitly stipulated that all requisite documents must be submitted by October 25, 2024, with clear consequences for non-compliance. He emphasized that despite two extensions with substantial late fees, the petitioner failed to meet even these extended deadlines.
Broader Implications for Public Recruitment
The court's decision reinforces fundamental principles governing public employment in India. Recruitment to public posts must be conducted with certainty, transparency, and equal opportunity for all eligible candidates. The judgment underscores that public employment processes must maintain uniformity and strict adherence to prescribed timelines to ensure fairness.
Justice Pillai observed that "granting individual relaxation on equitable or sympathetic considerations would not only violate the settled principles of service jurisprudence but would also set an unhealthy precedent, eroding the sanctity of the recruitment process." The court found no evidence of illegality, arbitrariness, or violation of statutory provisions that would warrant interference with the concluded selection process.
This ruling serves as an important reminder to all recruitment candidates about their responsibility to adhere strictly to published deadlines and procedures. It also reinforces the judiciary's commitment to maintaining the integrity and fairness of public employment systems across India.
