OBC Certificates Issued To Candidate Before Or After Dates Mentioned In Recruitment Advertisement Are Not Valid: Delhi High Court

The Delhi High Court has held that caste certificates issued before or after the timeframe stipulated in a recruitment advertisement are not relevant for the purpose of granting reservation to a candidate.In the case at hand, relating to recruitment of Security cum Fire Guard at AIIMS in the financial year 2022-2023, a division bench of Justices Navin Chawla and Madhu Jain said,“the Advertisement unambiguously stipulates that only valid NCL-OBC category certificates, issued within the period from 01.04.2022 to 31.03.2023, shall be considered valid. Any certificate issued either before or after this period shall not be deemed valid.”Petitioners applied for the advertised post under the OBC category. 12 seats were reserved for the same but the condition was that NCL-OBC certificate issued before or after 1.4.2022 to 31.3.2023, will not be considered valid.Petitioners claimed that they were in possession of certificates issued on 14.06.2017 and 02.12.2016 respectively and the competent authority, in the said certificates, had explicitly stated that “This certificate is valid for the financial year 2022-23”.AIIMS however denied reservation and CAT endorsed this order. Aggrieved, they approached the High Court.Petitioners contended they were in possession of previous OBC-NCL certificates, therefore their status as OBC-NCL was not disputed.The High Court however noted that the recruitment advertisement specifically mandated that only certificates issued within the financial year 2022-23, that is, between 01.04.2022 to 31.03.2023, would be considered valid. “The certificates relied upon by the petitioners were admittedly not issued between the given dates,” it said.Reliance was placed on Sakshi Arha v. Rajasthan High Court & Ors. (2025) where the Supreme Court held that category certificates must be valid as per the prescribed timeline mentioned in the advertisement. The Court also made it clear that mere possession of earlier certificates does not establish eligibility if the current certificate requirements are not met within the stipulated timeframe.As such, the plea was dismissed.Appearance: Mr.A.K.Trivedi, Mr.Dhruv Kothari and Mr.Yash Jangra, Advs for PetitionersCase title: Himanshu Yadav & Anr. v. AIIMS & Anr.Citation: 2025 LiveLaw (Del) 1308Case no.: W.P.(C) 13428/2025Click here to read order

OBC Certificates Issued To Candidate Before Or After Dates Mentioned In Recruitment Advertisement Are Not Valid: Delhi High Court

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