Summary
| Category | Data |
|---|---|
| Court | Supreme Court of India |
| Case Number | C.A. No.-000051-000051 – 2026 |
| Diary Number | 2019/2020 |
| Judge Name | HON’BLE MR. JUSTICE J.K. MAHESHWARI |
| Bench |
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| Precedent Value | Binding authority of Supreme Court interpreting Exam Rules and Cadre Allocation Policy for IFS |
| Overrules / Affirms | Sets aside Karnataka High Court and CAT orders; affirms that any stage relaxation bars adjustment against unreserved vacancies |
| Type of Law | Administrative / Service Law (IFS cadre allocation) |
| Questions of Law | Whether a reserved-category candidate who availed relaxation in the Preliminary Examination can be treated as “Insider General” for cadre allocation against an unreserved vacancy when later merit exceeds general cut-off? |
| Ratio Decidendi |
The IFS examination is two-tiered; preliminary marks are integral to eligibility. Rule 14(ii) proviso bars any SC/ST/OBC candidate who avails “relaxed standards” at “any stage of examination” from adjustment against unreserved vacancies. Conjoint reading of Rules 1, 13, 14, 17 and Paragraph 9 of the Cadre Allocation Policy shows that only candidates selected on “general standards” throughout—without concessions—may claim unreserved posts. A reserved candidate who qualifies prelim under relaxation must compete only for reserved-category vacancies despite higher final merit. |
| Judgments Relied Upon |
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| Logic / Jurisprudence / Authorities Relied Upon by the Court |
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| Facts as Summarised by the Court | A Scheduled Caste candidate (Respondent 1) qualified prelim with 247.18 (SC cut-off 233, Gen 267), then topped in final merit (rank 19) over a General candidate (rank 37). Two Karnataka IFS vacancies existed: General Insider and OBC Outsider. Government allocated General Insider to the General candidate and SC to Tamil Nadu. CAT and Karnataka HC granted SC candidate the General Insider post. |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All courts and tribunals adjudicating IFS-service and reservation issues |
| Persuasive For | Union Public Service Commission; Ministries issuing service notifications |
| Overrules | Karnataka High Court judgment in WP Nos. 18947/2016 & 54254/2016; CAT Bangalore Bench order |
| Distinguishes |
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| Follows |
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What’s New / What Lawyers Should Note
- Even a preliminary-stage relaxation for reserved candidates is “any stage of examination” under Rule 14(ii) proviso, barring them from unreserved vacancies.
- Integral nature of the screening tier means concessions cannot be ignored at cadre allocation.
- Conjoint reading of Exam Rules 2013 and Cadre Allocation Policy is mandatory to determine eligibility.
- Lawyers can cite this to resist reservation-to-general migration in service/post-allocation matters.
- Upholds meritocracy: higher final merit alone cannot override “any stage” concessions.
Summary of Legal Reasoning
- IFS exam is two-tiered: Rule 1 requires preliminary qualification for main exam and interview.
- Rule 13 proviso allows UPSC to relax prelim/main cut-offs for SC/ST/OBC to fill reserved seats.
- Rule 14(ii) proviso states any SC/ST/OBC candidate availing “relaxations/concessions in eligibility or selection criteria at any stage” is ineligible for unreserved vacancies.
- Rule 17 and Paragraph 9 of Cadre Allocation Policy confirm only those on “general standards” throughout may claim unreserved cadre posts.
- Reserved candidate here got prelim entry via relaxation—cannot be treated as “general standard” selectee despite superior final rank.
- Relied on precedents (Deepa E.V., Gaurav Pradhan, Niravkumar Dilipbhai, Sajib Roy) barring concession-takers from unreserved posts.
- Distinguished cases (Jitendra Kumar Singh, Ajithkumar P., Vikas Sankhala) with different rules or non-statutory prelims.
Arguments by the Parties
Petitioners (Union of India & Respondent 3)
- Exam Rules 2013 Rule 14 and Cadre Allocation Policy bar any reserved-category candidate who avails relaxation “at any stage” from claiming unreserved posts.
- “Any stage of examination” includes the preliminary screening; SC candidate used relaxed SC cut-off.
- Reliance on Deepa E.V., Gaurav Pradhan, Niravkumar Dilipbhai, Union of India v. Sajib Roy.
Respondent 1 (SC candidate)
- Preliminary exam is mere screening; marks are not counted in final merit (Appendix I, Exam Rules 2013).
- Having outscored the General candidate in main exam + interview, he met “general qualifying standard.”
- Denial violates meritocracy and Articles 14 & 16.
- Relied on Jitendra Kumar Singh, Ajithkumar P., Vikas Sankhala.
Factual Background
A Scheduled Caste candidate and a General candidate sat the 2013 IFS prelim. SC cut-off was 233, Gen 267; SC scored 247.18 under SC relaxation, Gen scored 270.68. Both passed main exam and interview: SC rank 19, Gen rank 37. Karnataka had two vacancies—General Insider and OBC Outsider. Government notification gave General Insider to Gen candidate, SC to Tamil Nadu. SC challenged in CAT (allowed), HC (affirmed), prompting these appeals.
Statutory Analysis
- Rule 1: Two-tier IFS exam—prelim screening then main + interview.
- Rule 13+proviso: UPSC may relax prelim/main cut-offs for SC/ST/OBC to fill reserved seats.
- Rule 14(i): Post-interview general merit list; general qualifying standard for unreserved vacancies.
- Rule 14(ii)+proviso: SC/ST/OBC may be recommended on relaxed standard but “any” relaxation at “any stage” disqualifies from unreserved adjustment.
- Rule 17 & Cadre Allocation Policy ¶9: Reserved candidate selected on general standards may claim unreserved post; else confined to reserved vacancies per merit/preferences.
Alert Indicators
- ✔ Precedent Followed