Updated OBC-NCL Certificate Can Be Submitted After Cut-Off Date In Central University Recruitment: Tripura High Court
The Tripura High Court has held that an OBC-NCL certificate is merely proof of an existing social status and not an acquired qualification, observing that candidates applying to Central Universities may submit updated OBC-NCL certificates even after the application cut-off date. The Court upheld the appointment of an Associate Professor in Tripura University, ruling that Government of...
The Tripura High Court has held that an OBC-NCL certificate is merely proof of an existing social status and not an acquired qualification, observing that candidates applying to Central Universities may submit updated OBC-NCL certificates even after the application cut-off date.
The Court upheld the appointment of an Associate Professor in Tripura University, ruling that Government of India Office Memorandums permit provisional consideration of SC, ST and OBC candidates on the basis of prima facie proof, subject to subsequent submission of formal certificates.
Division Bench of Chief Justice M.S. Ramachandra Rao and Justice Biswajit Palit remarked that: “An OBC-NCL Certificate is mere evidence of a fact which already exists, while a technical/academic qualification certificate refers to the acquisition of qualification. Failure to produce the certificate at the time of submission of application should not be treated as fatal. The Office Memorandum permits a candidate to submit his/her OBC-NCL Certificate even after the cut-off date and even at the time of joining, if selected.”
Background:
The case arose out of a recruitment advertisement issued by Tripura University on July 19, 2023 for the post of Associate Professor in the Department of Pharmacy reserved for OBC-NCL candidates. The advertisement stipulated that eligibility conditions were required to be fulfilled on or before August 24, 2023, and applications for reserved category posts had to be supported by valid and updated certificates in the prescribed Government of India format.
Both the appellant, Dr. Rajat Ghosh, and respondent no.7 applied for the post. Respondent no.7 was ultimately selected following interviews conducted on November 20, 2023. The appellant challenged the appointment on the ground that respondent no.7 did not possess a valid updated OBC-NCL certificate before the cut-off date and obtained such certificate only on December 12, 2023.
The University defended the selection by stating that respondent no.7 had uploaded an OBC certificate dated August 13, 2015 issued by the competent authority in Madhya Pradesh along with an income certificate dated June 8, 2023 during the online application process and document verification stage. The University maintained that these documents sufficiently established his eligibility for consideration under the OBC-NCL category.
The Single Judge had dismissed the writ petition after relying upon an Office Memorandum dated October 8, 2015 issued by the Department of Personnel and Training, Government of India, concerning verification of claims of SC, ST and OBC candidates. The memorandum stated that where a candidate is unable to produce the prescribed caste certificate, provisional appointment could still be granted on the basis of prima facie proof, subject to furnishing the certificate within a reasonable time.
The Single Judge further observed that an OBC-NCL certificate merely evidences an existing social status and is distinct from an educational or technical qualification. Therefore, delayed production of such certificate could not invalidate the candidature where prima facie proof already existed.
The High Court held that Tripura University, being a Central University, was bound by the Office Memorandums issued by the Government of India. The Bench noted that both the 2015 and subsequent Office Memorandum dated March 29, 2023 expressly permitted provisional consideration of candidates belonging to SC, ST and OBC categories on the basis of prima facie proof pending submission of formal certificates.
The High Court distinguished the decision on the ground that it related to recruitment governed by the Rajasthan Judicial Service Rules, 2010, where the Government of India Office Memorandums were inapplicable.
Thus, the High Court dismissed the appeal.
Case Name: Dr. Rajat Ghosh V/s Tripura University
Case No.: W.A. No. 43 of 2025
Date of Decision: 14.05.2026