Shruti Vs Office of the Principal District and Sessions Judge & Ors.

The Petitioner applied for the post of Personal Assistant in Delhi District Courts and Family Courts pursuant to advertisement dated 12^th January, 2024, with the last date for submission of applications being 8^th February, 2024. The Petitioner participated in the Tier-I Computer Based Examination held on 8^th March, 2024, and upon declaration of results on 15^th May, 2024, was shortlisted for Tier-II examination, which she undertook on 1^st June, 2024. Thereafter, she participated in the Tier-III skill test (shorthand examination) and subsequently in the Tier-IV interview held on 9^th February, 2025. Upon declaration of results on 27^th February, 2025, the Petitioner was declared successful and was issued an offer of appointment

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W.P.(C) 3348/2026 Page 1 of 5

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dated 9^th April, 2025.

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On 15^th April, 2025, the Respondents conducted verification of the Petitioner9s documents. The Petitioner furnished an OBC-NCL certificate dated 30^th April, 2025 issued by the Government of NCT of Delhi. Subsequently, by communication dated 26^th December, 2025, the Petitioner9s candidature was cancelled. Aggrieved thereby, the present petition has been filed.

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The Court has heard Mr. Anuj Aggarwal, counsel for the Petitioner. The grounds urged in the present petition are substantially identical to those considered by this Court in W.P.(C) 3065/2026, titled David Kumar v. Office of the Principal District and Sessions Judge (HQS) & Ors. , decided on 11^th March, 2026, which also arose out of the same recruitment process and advertisement. In that case as well, the candidate had furnished an OBCNCL certificate issued beyond the prescribed cut-off date.

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In David Kumar , this Court, after examining the terms of the advertisement, declined to interfere with the cancellation of candidature where the candidate neither possessed nor had applied for the requisite OBC-NCL certificate before the cut-off date. It was not a case of delayed issuance of certificate for reasons attributable to the authorities, but one where the candidate had not taken steps within time. In that context, relying upon the decision of the Supreme Court in Sakshi Arha v. Rajasthan High Court¹ , the Court held that such non-compliance with the stipulated timeline could not be condoned.

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The ratio of David Kumar squarely applies to the present case. The Petitioner has not demonstrated that she had applied for the requisite OBC-

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W.P.(C) 3348/2026 Page 2 of 5

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NCL certificate prior to the cut-off date, nor is this a case where the certificate was issued belatedly due to administrative delay despite a timely application. The requirement under the advertisement to possess the relevant certificate by the cut-off date is explicit and admits of no ambiguity.

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Mr. Anuj Aggarwal, counsel for the Petitioner, however, submits that in David Kumar , certain rulings were not brought to the notice of the Court. He places reliance on the decision of the Division Bench in W.P.(C) 505/2026, titled All India Institute of Medical Science (AIIMS) v. Praveen , dated 15^th January, 2026. The said decision also related to a candidate belonging to the OBC-NCL category. In that case, the candidate had produced an OBC-NCL certificate which had been issued earlier in 2015 and was renewed for the relevant period, along with material demonstrating that he continued to belong to the non-creamy layer category. However, his candidature was rejected at the stage of document verification in 2023 on the ground that the certificate did not fall within the prescribed time period. The Central Administrative Tribunal (8CAT9) ruled in favour of the candidate, and the challenge thereto was rejected by the Division Bench. The Court observed that the gross delay in scrutiny of documents was attributable to AIIMS, and that the candidate had demonstrated continuous eligibility. In such circumstances, it was held that the candidate could not be deprived of appointment on a hyper-technical view, and accordingly, the decision of the CAT was not interfered with.

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Mr. Aggarwal has also relied upon the decision in All India Institute of Medical Sciences v. Ravi Kumar [LPA 232/2024, dated 20 March, 2024], wherein the Division Bench upheld the decision of the Single Judge in

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1 2025 INSC 463.

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relation to a candidate claiming benefit of OBC-NCL category. A perusal of the said decision reveals that the view taken by the Single Judge, as affirmed by the Division Bench, was primarily founded on the decision of the Supreme Court in Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board² , as well of as of this Court in Anil Kumar v. Union of India³ .

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The said decision further notes that, at the relevant stage, the question arising in Sakshi Arha had been referred to a larger Bench. The Division Bench distinguished Sakshi Arha on facts by observing that the issue therein pertained to submission of caste certificate beyond the last date prescribed in the advertisement, whereas in the case before it, the candidate had already furnished a caste certificate within time and had subsequently submitted an updated certificate. The Court also proceeded on the basis that the requirement prescribing a particular time frame for issuance of the OBCNCL certificate was arbitrary and lacked a rational nexus with the object of reservation. However, the factual and legal position in the present case is materially different. Moreover, the observations of the Supreme Court in Sakshi Arha on the requirement and relevance of a valid OBC-NCL certificate cannot be ignored.

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In the opinion of this Court, the present case is squarely governed by the principles noticed in Sakshi Arha , as applied in David Kumar . The decisions cited by Mr. Aggarwal do not persuade this Court to take a different view.

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Accordingly, the present writ petition is disposed of along with

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2 (2016) 4 SCC 754.

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3 2013 SCC OnLine Del 1401.

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W.P.(C) 3348/2026 Page 4 of 5

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pending applications.

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SANJEEV NARULA, J

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MARCH 17, 2026/ nk

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W.P.(C) 3348/2026 Page 5 of 5

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Shruti v. Office of the Principal District and Sessions Judge & Ors.

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Shruti v. Office of the Principal District and Sessions Judge & Ors.

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