Reservation Can't Justify “Complete Abandonment Of Merit”: Rajasthan HC Quashes Selection Of 1200+ Class-IV Candidates With Near-Zero Marks

The bench of Justice Anand Sharma observed that public employment was not charity and every public post, however small it might be, carried public duties and responsibilities. It was held that the state could not assume that for Class-IV posts, no minimum merit or competence was required.

“…the State while making public recruitment is under constitutional obligation to ensure that minimum standards are maintained so that public employment does not become an object of ridicule.”

“…constitutional goals of social justice and reservation must operate in harmony with maintenance of minimum standards in public administration. Reservation prescribed for disadvantaged sections cannot translate into complete dilution of merit to the extent where public institutions themselves lose credibility.”

The Court held that the act of selecting such candidates reduced the public recruitment to a “ritualistic exercise and devoid of any standards”. It was stated that the act struck at the root of institutional integrity and public confidence in the recruitment processes.

For context, the Court was hearing petitions filed by two unsuccessful candidates of the recruitment process of Class-IV employees, who had applied under the reserved category. The petitioners had secured marks in negative.

It was the petitioners' contention that despite the vacancies remaining unfilled under the respective categories, they were not selected merely on account of securing negative marks, despite no minimum qualifying criteria being prescribed.

Further, it was submitted that candidate belonging to some other reserved categories were selected despite securing normalized marks as low as 0.0035.

After hearing the contentions, and perusing other records, the Court highlighted the list of selected candidates that included more than 1200 candidates who had originally secured negative marks, and even after normalization, their marks were virtually zero. Most of these candidates fell within reserved categories.

The Court held that the constitutional mandate of providing reservation and adequate representation in public employment could not be stretched to the extent where minimum standards of suitability and efficiency were ignored.

Reservation could not become a mechanism to legitimize appointments of “wholly unsuitable candidates who have demonstrated complete lack of merit or basic competence”.

Reference was made to Article 335 of Constitution to underscore the mandate of maintaining efficiency of administration while considering claims of reserved categories in services and posts.

The Court further rejected the argument of no prescription of minimum qualifying marks, and held that, “Merely because the rules may not expressly prescribe minimum qualifying marks does not absolve the State from its constitutional obligation to maintain minimum standards of fairness, reasonableness and suitability in public appointments.”

It was stated the every executive action had to satisfy the test of reasonableness under Article 14. Prescribing no minimum qualifying marks and consequentially selecting candidates who secured virtually zero was arbitrary, irrational and thus unconstitutional.

With respect to the concept of normalization, the Court observed that the process could not be utilized to artificially elevate candidates who otherwise failed to demonstrate bare minimum merit.

“The doctrine of equality under Articles 14 and 16 of the Constitution of India does not envisage equality in irrationality. The State cannot justify arbitrary appointments merely by referring to reservation policy. Relaxation in qualifying standards may be permissible within constitutional limits, however, complete abandonment of standards is impermissible.”

While quashing the selection of such candidates, it was held that acceptance of such selection would amount to judicial approval of complete erosion of standards in public employment.

Accordingly, the State was directed to undertake fresh exercise for preparation of merit/select list to the extent of categories in question.

Title: Vinod Kumar v State of Rajasthan & Anr., and other connected matters

Citation: 2026 LiveLaw (Raj) 207

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