Supreme Court Rules: Candidates Using Reservation Benefits Cannot Claim General Category Seats

New Delhi: The Supreme Court has delivered a significant judgment on the use of reservation benefits in competitive exams. The apex court ruled that candidates who avail of reservation concessions under categories such as SC/ST cannot later claim a seat under the unreserved (general) category, even if their final rank surpasses that of general category candidates.

Case Background
The ruling arose from a dispute related to the 2013 Indian Forest Service (IFS) Examination, which comprises two stages: the Preliminary Exam and the Main Exam, followed by an interview. For the Preliminary Exam, the general category cut-off was 267 marks, while the SC category cut-off was 233 marks. SC candidate G. Kiran cleared the exam by benefiting from the relaxation, scoring 247.18 marks. General category candidate Antony S. Mariappa scored 270.68 marks, surpassing the general cut-off.

After the Main Exam and interview, Kiran secured the 19th rank in the final merit list, ahead of Mariappa, who ranked 37th. However, during cadre allocation, only one general insider seat was available in Karnataka, which was allotted to Mariappa, while Kiran was assigned to the Tamil Nadu cadre.

High Court Decision and Appeal
Kiran challenged the allocation at the Central Administrative Tribunal (CAT) and later at the Karnataka High Court, both of which ruled in her favor, citing her superior final rank.

Supreme Court Reversal
The Union of India appealed to the Supreme Court, which overturned the High Court’s judgment. A bench of Justices J.K. Maheshwari and Vijay Bishnoi emphasized that the IFS exam follows an integrated selection process, and eligibility for general category consideration requires that no reservation benefit is used in any stage of the exam.

Citing Rule 14(ii) of the IFS Exam regulations, the court clarified that Kiran had availed of the SC category relaxation in the Preliminary Exam. Therefore, she cannot be considered for unreserved seats, even if her final rank exceeds that of general category candidates.

Justice Maheshwari noted, “Once a candidate benefits from a reserved category concession, they cannot claim an unreserved vacancy. The relaxation provided in the Preliminary Exam cannot be ignored in subsequent stages.” The judgment also referenced the precedent set in Union of India vs. Sajib Roy, reinforcing that reservation benefits cannot be retroactively waived for general category allocation unless explicitly permitted by rules.

This ruling underscores the principle that reservation benefits are binding throughout the examination process and cannot be exploited to claim unreserved seats.