The Patna High Court has clarified that a candidate who declares an incorrect reservation category in a government recruitment application—and cannot substantiate it with original documents during verification cannot seek relaxation by shifting to another category after the selection stages are over. In a writ petition concerning recruitment to the Bihar Police under Advertisement No. 01/2017, the Court dismissed the petitioner’s plea for appointment as Constable, holding that a “mismatch in application form data with original documents” renders the candidature itself invalid.

The petitioner had applied online for the post of Constable. During the online form submission on 15 August 2017, the reservation category was entered as Backward Class (BC), though the petitioner actually held an Extremely Backward Class (EBC) certificate. The candidate appeared in and passed the written examination held on 15 October 2017 and later cleared the Physical Evaluation Test conducted on 16 March 2018. The discrepancy surfaced only at the stage of document verification, when the authorities found that the original certificate produced was for EBC, not BC as declared in the application. The recruitment board therefore cancelled the candidature citing a “mismatch” between the form and the original documents.

Before the High Court, the petitioner argued that the error in selecting the reservation category was inadvertent and that, at the very least, the candidature should be considered under the General (unreserved) category. The Court noted that the advertisement and application conditions explicitly warned that incorrect entries—particularly concerning reservation—would lead to cancellation of candidature. The application form itself contained a declaration (Clause 20) requiring the candidate to affirm that if any information was found wrong or incorrect, the candidature would be rejected.

The recruitment board highlighted the scale of the process: over 10.5 lakh candidates appeared in the written examination. It asserted that the category selected by each applicant governed crucial aspects of scrutiny and cut-offs, and that the advertisement clearly stipulated rejection where a reservation entry was wrong. The board further informed the Court that the final result had been published on 11 June 2018, with 9,839 candidates declared successful against 9,900 vacancies; 61 positions remained unfilled due to non-availability of suitable Gurkha candidates, and recommendations for appointment were already sent on 13 June 2018.

In its reasoning, the Patna High Court relied on two Division Bench precedents. First, in Anil Kumar v. State of Bihar (2013), the Division Bench held that where a candidate’s application claimed a particular category but original documents did not support that claim, the candidate could not be treated in some other category merely because they might otherwise qualify. That appeal was dismissed in limine. Second, in Central Selection Board of Constable v. Raj Kumar (2017), the Division Bench reiterated that a wrong declaration in the application form, which cannot be substantiated by original documents, invalidates the candidature: mis-categorization is material to the selection process and even more so at the stage of appointment.

Applying these principles, the Court concluded that once a candidate has given a wrong declaration regarding reservation in the application form and cannot substantiate it with original documents, the candidature is invalid. Because the petitioner declared BC but could produce only an EBC certificate, the cancellation was justified. The writ petition was therefore dismissed on 5 April 2021.

Significance or Implication of the Judgment

This decision is significant for both the public and recruiting authorities:

• It underscores the legal weight of the declarations made in online applications for public employment. Candidates must ensure that their reservation category and other particulars exactly match their original documents. Errors—even inadvertent—can be fatal to candidature at the verification stage.
• It affirms the integrity of the recruitment process in mass selections, where uniform application of declared categories is essential. With more than a million applicants in this recruitment cycle, the Court recognized that allowing post facto corrections or category shifts would compromise fairness and create administrative chaos.
• For government departments and recruiting bodies, the ruling validates strict enforcement of advertisement conditions and candidate declarations, including clauses that provide for automatic rejection upon detection of incorrect information.
• For candidates, the lesson is practical: double-check reservation category selection before final submission, and ensure that the certificates (caste, domicile, etc.) align precisely with what is entered in the application portal. Seeking consideration under the General category after disclosing a different reserved category, or vice versa, is unlikely to succeed once verification exposes the mismatch.

Legal Issue(s) Decided and the Court’s Decision with reasoning

• Whether a candidate who declared one reservation category in the application form but produced an original certificate for a different category at verification could be appointed or considered under another category (e.g., General)
  – Decision: No. A wrong declaration of reservation category, not supported by original documents, invalidates the candidature; post facto correction or shifting category is impermissible. Reasoning: The advertisement and candidate declaration (Clause 20) warned of rejection for incorrect entries; Division Bench precedents (Anil Kumar; Raj Kumar) squarely govern the situation.
• Whether the recruitment board acted lawfully in cancelling the candidature for “Mismatch in Application Form Data with Original Documents”
  – Decision: Yes. The cancellation was in accordance with the advertisement terms; the petitioner’s BC declaration could not be substantiated and the original certificate was for EBC.
• Whether the process could be reopened or adjusted given that final results had been published and appointments recommended
  – Decision: No. The Court took note that results were published on 11 June 2018, recommendations were issued on 13 June 2018, and appointments followed; reopening was unwarranted.

Judgments Referred by Parties (with citations)

• Anil Kumar v. State of Bihar & Ors., 2013 (4) PLJR 1 (Division Bench). Relied on to argue that mis-declaration of category, not backed by documents, cannot be cured by treating the candidate under another category.
• Central Selection Board of Constable & Ors. v. Raj Kumar & Ors., 2017 (1) PLJR 599 (Division Bench). Cited for the proposition that wrong categorization is material to selection and invalidates candidature if not substantiated by originals.

Judgments Relied Upon or Cited by Court (with citations)

• Anil Kumar v. State of Bihar & Ors., 2013 (4) PLJR 1 (Division Bench). The Court extracted paras 4–7 and followed the ratio that contrary information in the application cannot be rectified by later claiming another category.
• Central Selection Board of Constable & Ors. v. Raj Kumar & Ors., 2017 (1) PLJR 599 (Division Bench). The Court quoted para 12, stating that a wrong declaration not supported by originals invalidates candidature.

Case Title
Petitioner v. State of Bihar & Ors. (name withheld)

Case Number
Civil Writ Jurisdiction Case (CWJC) No. 16836 of 2018

Citation(s)
2021(2) PLJR 352

Coram and Names of Judges
Hon’ble Mr. Justice Mohit Kumar Shah (Oral Judgment dated 05-04-2021)

Names of Advocates and who they appeared for

• For the petitioner: Mr. Kumar Malendu
• For the State (Respondents): Mr. Md. Nadeem Seraj, GP-5; Md. Iqbal Asif Niazi, AC to GP-5
• For the Central Selection Board of Constable (CSBC): Mr. Sanjay Pandey; Mr. Binod Kr. Mishra; Mr. Vivek Anand Amritesh

Link to Judgment
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