25 January 06 2026

Supreme Court: Reserved Category Candidates Eligible for General Category Posts [Rajasthan High Court & Anr. vs. Rajat Yadav & Ors. 2025] (CASE SUMMARY)

1. FACTS OF THE CASE: A MERIT PARADOX
In 2022, the Rajasthan High Court advertised 2,756 vacancies for Junior Judicial Assistants and Clerks. The selection involved a written test (300 marks) and a typing test (100 marks). When the written results came out, a strange situation occurred: because students from reserved categories (OBC, EWS, SC) performed so well, their "cut-off" marks were much higher than the General category cut-off. For example, the General cut-off was 196.34, while the OBC cut-off was 230.44. This meant a candidate with 210 marks was disqualified if they were OBC, even though they had scored much higher than General category candidates who were allowed to move to the next stage.

2. LOWER COURT DECISIONS: PROTECTING TALENT
The matter was first taken to the Rajasthan High Court. A Division Bench ruled in favor of the candidates in September 2023. The High Court stated that the "Open Category" is not a reserved quota for non-reserved people; it is an open pool based purely on merit. The court ordered the administration to redraw the lists so that anyone scoring above the General cut-off could proceed to the typing test.

3. THE ISSUE BEFORE THE SUPREME COURT: WHEN DOES MERIT COUNT
The High Court administration appealed to the Supreme Court. The central question was whether a meritorious reserved candidate should be treated as a "General" candidate during the shortlisting (middle) stage of an exam, or if this adjustment only happens at the final (appointment) stage.

4. ARGUMENTS FROM THE APPELLANT (THE RECRUITERS)
The High Court administration argued that shifting candidates to the General category at the shortlisting stage would give them a "double benefit". They claimed that according to past rules, a candidate’s "category" stays fixed until the very final merit list is made. They also argued that since the candidates participated in the exam knowing the rules, they shouldn't be allowed to challenge them later (a legal concept called "estoppel").

5. ARGUMENTS FROM THE RESPONDENTS (THE CANDIDATES)
The candidates argued that the General category is an "Open" space. They claimed that stopping a candidate with 220 marks while letting in someone with 196 marks—just because of their caste—is a violation of the Right to Equality under Articles 14 and 16 of the Constitution. They insisted that the most talented people should always fill the "Open" seats first, regardless of their background.

6. DISCUSSION OF LAWS AND RULES
The Supreme Court looked at the Rajasthan High Court Staff Service Rules, 2002. It noted that in this specific exam, the written test was not just a "pass/fail" screening but accounted for 75% of the total marks. Therefore, merit at this stage was vital and could not be ignored. The Court emphasized that "Open" seats are for anyone who qualifies on their own strength without using relaxations like age or fee waivers.

7. THE SUPREME COURT'S FINAL DECISION
On December 19, 2025, the Supreme Court dismissed the appeals and upheld the High Court's order. The Court ruled that:
I. Open is not a Quota: The General category must be filled first by the highest scorers from all categories.
II. No Double Benefit: A candidate who wins on merit isn't "using" a reservation; they are simply being rewarded for their talent.
III. Equality Matters: You cannot exclude a more meritorious person just because they belong to a reserved category.

8. ADVOCATE ALOK KUMAR’S OPINION: A WIN FOR FAIRNESS
This judgment is a significant step toward a merit-based society. It prevents the "Open Category" from being wrongly turned into a "reserved category for the upper castes". By ensuring that the smartest students—no matter their background—occupy the general seats, the ruling actually protects the reservation system. It ensures that quotas are kept for those who truly need them, while the most meritorious candidates are recognised for their individual hard work and excellence. By prioritising merit at every substantive stage of the selection process, the Court has dismantled the "rigid slot" approach that previously trapped talented candidates within their social labels. The ruling affirms that the "Open" category is not a reserved compartment for any group, but is a merit-based pool that is "open to all" regardless of caste, tribe, or gender. It corrects a fundamental unfairness where high performing candidates were being disqualified for belonging to a reserved category, effectively ensuring that reservation remains a tool for inclusion rather than a barrier to advancement. Ultimately, this strengthens the public service by ensuring that the most capable individuals those who outscore their peers without needing any extra help are selected purely on their own strength.

Author

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Adv. ALOK KUMAR
Advocate Serving Delhi NCR
Delhi High Court & District Courts
LL.B.▪︎Faculty of Law▪︎Delhi University


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