Background of the Case
On 15 December 2021, the Uttar Pradesh Subordinate Service Selection Commission issued an advertisement for 9,212 posts of Health Worker (Female). Ten per cent of the posts (921) were reserved for the Economically Weaker Section (EWS) category. The last date for submission of applications was 5 January 2022.
Candidates claiming EWS reservation were required to submit an Income and Asset Certificate in the exact prescribed Form-I (appended to the advertisement). Clause 8.3 of the advertisement mandated that the certificate must be issued on or before the last date of application and must relate to the financial year prior to the year of application (i.e., FY 2020-21 for applications submitted in early 2022).
Several candidates submitted EWS certificates that were defective in one or more of the following ways:
- Issued before the relevant financial year had even ended (e.g., January–February 2021 certificates claiming validity for FY 2020-21).
- Stated the wrong financial year (2019-20 instead of 2020-21).
- Did not mention the validity period at all.
- One certificate (Sunita Kumari) was dated 10 January 2022 but related to FY 2021-22.
The Commission rejected their EWS claims. The candidates approached the Allahabad High Court. The Single Judge allowed the writ petitions and directed issuance of fresh certificates. The Division Bench reversed the order, holding the certificates invalid. The matter reached the Supreme Court.
Supreme Court’s Key Holdings
- EWS Certificate Must Relate to the Correct Financial Year The Court reiterated that for recruitment in 2021-22, the certificate must reflect income and assets of FY 2020-21 (01.04.2020 to 31.03.2021). Certificates issued before 31 March 2021 or referring to an earlier year (2019-20) are invalid.
- Certificate Must Exist Before the Cut-Off Date The certificate must be in the candidate’s possession in the prescribed format on or before the last date of application (5 January 2022). Post-cut-off corrections or fresh certificates cannot be permitted once the selection process has advanced.
- Error in Certificate Goes to the Root of Eligibility Citing its earlier decisions in UPSC v. Gaurav Singh & Ors. (2024) 2 SCC 605 and Divya v. Union of India (2024) 1 SCC 448, the Supreme Court held that a certificate relating to the wrong financial year is not a mere technical defect — it fundamentally affects eligibility.
- No Relief on the Ground of “State’s Fault” The argument that the Tehsildar issued defective certificates and therefore candidates should not suffer was rejected. Candidates are duty-bound to obtain a correct certificate in terms of the advertisement. Most defective certificates were obtained before the advertisement was even published (January–February 2021), giving candidates ample time to apply for fresh ones.
- Public Recruitment Requires Strict Compliance The Court emphasised that large-scale online recruitments are processed through software. Any mismatch leads to automatic rejection. Allowing post-facto corrections would stall the entire process and prejudice thousands of other candidates.
Operative Order
The Supreme Court dismissed all appeals. The Division Bench judgment of the Allahabad High Court was upheld. No relief was granted to the petitioners.
Important Takeaways for Aspirants & Legal Practitioners
- EWS certificates are not interchangeable with income certificates used for other purposes. They must strictly follow the format and financial year prescribed in the advertisement.
- Timing is everything — the certificate must be issued after the relevant financial year ends and before the last date of application.
- Mere qualification in the written exam does not cure a defective reservation claim.
- Government job aspirants must verify the exact financial year requirement the moment the advertisement is published.
- Authorities issuing EWS certificates must be careful; however, the ultimate responsibility of submitting a valid certificate lies with the candidate.
Quote from the Judgment
“In such circumstances, if the certificate(s) relied upon by the appellants were not in respect of the financial year prior to the year of the application and were issued prior to even closure of the relevant financial year, there was an error apparent on the face of those certificates…” — Para 25
Why This Judgment Matters
This decision reinforces the Supreme Court’s consistent stand on reservation claims — substantial compliance is not enough; strict compliance with advertisement conditions is mandatory. It serves as a clear warning to candidates, issuing authorities, and selection commissions alike.
Case Details: Poonam Dwivedi & Ors. v. State of U.P. & Ors. (Civil Appeal Nos. of 2026 arising out of SLP (C) Nos. 4001-4002/2023, 20256/2023 & 22042-22043/2023) | 2026 INSC 351
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