Supreme Court clarifies that reserved candidates availing preliminary exam cut-off relaxation cannot claim general insider vacancies for cadre allocation
IF A RESERVED CATEGORY CANDIDATE SCORES HIGHER THAN GENERAL CANDIDATES IN MAIN EXAM, CAN THEY CLAIM GENERAL INSIDER VACANCY FOR CADRE ALLOCATION?
NO, IF THEY AVAILED PRELIM CUT-OFF RELAXATION. The Supreme Court has ruled that reserved category candidates who avail any relaxation or concession "at any stage of examination" - including preliminary exam cut-off - cannot be allocated against unreserved/general insider vacancies for cadre allocation. Even if they score higher than general candidates in the main examination, availing relaxation in the preliminary exam permanently bars migration to general vacancies.
Examination: Both G. Kiran (SC) and Antony Mariyappa (General) appear for IFS Preliminary Exam. Kiran scores 247.18, qualifies using SC cut-off 233 (General cut-off 267)
Final Merit List: Kiran ranks 19, Mariyappa ranks 37 in final merit based on main exam and interview
Cadre Allocation: UOI allocates Karnataka General Insider vacancy to Mariyappa (General), Tamil Nadu cadre to Kiran (SC)
Original Application: Kiran files OA before CAT seeking Karnataka General Insider vacancy
CAT Order: Tribunal allows OA, directs allocation of Karnataka General Insider vacancy to Kiran
High Court Decision: Karnataka HC affirms CAT order, emphasizes main exam merit
Supreme Court Judgment: Sets aside HC and CAT orders, upholds UOI's original allocation
| Legal Provision | What It Means | Application |
|---|---|---|
| Rule 14(ii) Proviso - Exam Rules 2013 | Candidates availing relaxation at any stage cannot be adjusted against unreserved vacancies | Preliminary exam cut-off relaxation bars general vacancy claim |
| Rule 1 - Exam Rules 2013 | IFS exam consists of two tiers (prelim + main) | Preliminary exam is integral stage, not just screening |
| Paragraph 9 - Cadre Allocation Policy | Reserved candidate selected on "general standards" eligible for unreserved vacancy | "General standards" means no relaxation at any stage |
| Deepa E.V. vs Union of India (2017) | Availing age relaxation bars consideration against unreserved category | Applied by analogy to exam cut-off relaxation |
The qualifying criteria applicable to general category candidates without any relaxation or concession at any stage of examination.
Lower qualifying criteria applicable to reserved category candidates (SC/ST/OBC) under government reservation policy.
The process of assigning successful candidates to specific state cadres in All India Services based on merit, preference, and category.
A vacancy in a candidate's home state cadre, preferred by most candidates for personal and family reasons.
"The phrase 'any stage of examination' in Rule 14(ii) proviso of Exam Rules 2013 includes the preliminary examination stage. A reserved category candidate who avails the benefit of relaxed cut-off marks in the preliminary examination, though may secure higher marks than general category candidates in the main examination, cannot be treated as selected on 'General Standards' and is therefore not eligible for allocation against unreserved vacancies for cadre allocation purposes."
This judgment provides clarity on the operation of reservation policies in multi-stage examinations. It balances the need for affirmative action with the principles of meritocracy in final allocations, ensuring that the benefit of relaxation in early stages doesn't translate into preferential treatment in cadre allocation against general vacancies.
This content is for informational purposes only and does not constitute legal advice. Consult a qualified legal professional for specific legal guidance. The information provided is based on judicial interpretation and may be subject to changes in law.
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