The Court has unequivocally held that once the last date for application and the date of the examination have passed, courts cannot grant relaxation or alter the cut-off date for upper age limit eligibility. This judgment strictly affirms existing precedent, providing binding guidance to subordinate courts, public service commissions, and applicants in the context of competitive recruitment examinations.
Summary
| Category | Data |
|---|---|
| Case Name | WPC/5949/2024 of AMAR PRABHAT Vs THE STATE OF JHARKHAND THROUGH CHIEF SECRETARY, CNR JHHC010326212024 |
| Date of Registration | 28-10-2024 |
| Decision Date | 02-09-2025 |
| Disposal Nature | Dismissed |
| Judgment Author | Sri Ananda Sen, J. |
| Court | High Court of Jharkhand |
| Bench | Single Judge Bench |
| Precedent Value | Binding precedent for subordinate judiciary in Jharkhand; persuasive for other jurisdictions |
| Overrules / Affirms | Affirms existing law on age relaxation and cut-off dates in competitive exam recruitments |
| Type of Law | Service Law / Public Employment / Recruitment |
| Questions of Law | Whether the upper age limit cut-off for appointment in public service can be relaxed or altered after the examination date |
| Ratio Decidendi |
The Court held that, since the petitioners had already crossed the upper age limit and approached the court after the last date for filing forms (and after the examination was held), no relaxation or judicial intervention is permissible. Advertised deadlines and eligibility requirements in public recruitment must be adhered to strictly, especially after selection processes are concluded. The petition was consequently dismissed. |
| Facts as Summarised by the Court | Petitioners sought relaxation of upper age limit after the last date for application; the examination pursuant to the relevant advertisement had already been held when the writ was filed. |
| Citations | 2025:JHHC:26641 |
Practical Impact
| Category | Impact |
|---|---|
| Binding On | All subordinate courts and authorities within Jharkhand; all future recruitment by Jharkhand Public Service Commission (JPSC) |
| Persuasive For | High Courts of other states, Central Administrative Tribunal, Supreme Court |
What’s New / What Lawyers Should Note
- The Court reaffirms that relaxation of upper age limits or alteration of the cut-off date cannot be sought for the first time after the closure of the application process or after the conduct of the recruitment examination.
- Lawyers should advise clients that challenging age criteria post-deadline and post-examination will not be entertained by the Court.
- This decision provides clear binding authority for rejecting similar belated age relaxation/eligibility claims in future writ petitions.
Summary of Legal Reasoning
- The Court noted that the petitioners had crossed the upper age limit prescribed for appointment and that the selection examination had already been held as per advertisement.
- It was brought to notice during arguments that the petition was filed after both the deadline for application and the holding of the examination.
- Relying on principles of strict compliance with recruitment notifications and the finality of completed selection processes, the Court refused to grant any relief or consider relaxation of upper age limit at such a belated stage.
- The petition was dismissed on this ground without reference to individual equities or exceptional circumstances, thereby reaffirming administrative certainty and non-interference in concluded recruitment processes.
Arguments by the Parties
Petitioner:
- Sought relaxation of upper age limits for appointment.
- Prayed for judicial fixation of the cut-off date for age eligibility.
Respondent:
- Submitted that the examination under the recruitment advertisement had already been conducted.
- Pointed out that the petitioners had approached the Court after the last date for submitting application forms.
Factual Background
The petitioners filed a writ in the High Court seeking relaxation of the upper age limit for purposes of appointment under a recruitment process conducted by the Jharkhand Public Service Commission. At the time of filing the petition, both the last date for submitting application forms and the actual examination under the relevant advertisement had already passed. The petitioners had crossed the prescribed upper age limit prior to seeking judicial intervention.
Statutory Analysis
- The judgment refers to the legal framework governing recruitment and age eligibility for public appointments as set out in the advertisement for the competitive examination.
- The Court did not engage in interpretation or expansion of any particular statutory section but relied on the established principle that once a recruitment schedule has run its course, courts cannot intervene to alter eligibility terms or deadlines post facto.
Dissenting / Concurring Opinion Summary
No dissenting or concurring opinions are present in the judgment.
Procedural Innovations
No new procedural rules, guidelines, or innovations are set out or prescribed in the judgment.
Alert Indicators
- ✔ Precedent Followed – The High Court strictly adheres to and reinforces existing judicial precedent regarding post-deadline relaxations in recruitment.
Citations
2025:JHHC:26641