Orissa High Court Delivers Landmark Ruling on Age Relaxation
The Orissa High Court has made a significant ruling regarding age relaxation for government jobs. Justice S K Panigrahi delivered this judgment on January 15, 2024. The court clearly stated that candidates from reserved categories cannot claim age relaxation when applying for unreserved posts.
Key Legal Principle Established
Justice Panigrahi emphasized a crucial legal principle in his judgment. He stated that migration from reserved to unreserved category is only permissible when recruitment rules or advertisements explicitly authorize it. Where such migration is not contemplated, candidates cannot use age relaxation benefits to bypass eligibility conditions for unreserved positions.
The court considered a specific petition challenging Odisha Hydro Power Corporation Limited's decision. OHPCL had refused to accept an SEBC candidate's application for a management trainee position in the human resources department.
Background of the Case
OHPCL published an advertisement on November 7, 2025, inviting applications for management trainee positions. The corporation set an age limit of 21 to 32 years for these posts. They offered age relaxation of five years for SC, ST, SEBC, and women candidates. Persons with disabilities received ten years of relaxation.
However, the advertisement clearly specified that no vacancies were earmarked for the SEBC category. The petitioner, an MBA graduate belonging to the SEBC category, was 35 years and 5 months old on the cutoff date. He applied under the unreserved category while claiming SEBC age relaxation benefits.
OHPCL rejected his application firmly. The corporation maintained that age relaxation could not be extended when no posts were reserved for that particular category.
Court's Detailed Reasoning
Justice Panigrahi reiterated established legal principles in his comprehensive judgment. He underlined that recruitment policy formulation falls exclusively within the employer's domain. This includes fixing age limits, determining category-wise vacancies, and granting relaxations.
The court emphasized that constitutional courts should refrain from interfering in such matters. Justice Panigrahi noted that the advertisement unequivocally disclosed that no SEBC vacancies existed in the concerned cadre. Therefore, the petitioner could not claim age relaxation benefits as a matter of right.
The judgment found no merit in the petitioner's challenge. The court declared the petitioner ineligible for consideration against the unreserved category. Consequently, the court dismissed the petition entirely.
Broader Implications
This ruling clarifies important aspects of recruitment processes in government and public sector organizations. It reinforces the principle that reserved category benefits apply specifically to reserved positions. Candidates cannot automatically transfer these benefits to unreserved posts without explicit authorization.
The judgment serves as a reminder to both employers and job applicants about recruitment rule interpretations. Employers must clearly specify category-wise vacancies and relaxation provisions. Candidates must carefully review advertisement terms before applying for positions.
This case originated from Cuttack, where the Orissa High Court is located. The ruling will likely influence similar cases across the state and potentially beyond. It strengthens the legal framework governing public sector recruitment in India.
