Tripura High Court: In an appeal assailing recruitment of an Other Backward Classes (OBC) candidate in University for submitting caste certificate after the prescribed cut-off date, the Division Bench of M.S. Ramachandra Rao*, CJ., Biswajit Palit, J., held that Department of Personnel and Training (DoPT) Office Memorandums permitted production of the caste certificate at a later date despite the advertisement prescribing a cut-off date.
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Background
The present dispute arose out of the recruitment process initiated by Tripura University for the post of Associate Professor in the Department of Pharmacy, reserved for Other Backward Classes Non-Creamy Layer (OBC-NCL) candidates. The advertisement stated that candidates were required to fulfil the eligibility conditions on or before the last date for submission of applications, and further mandated submission of a valid and updated OBC-NCL certificate in the format prescribed by the Government of India.
Both the appellant and Respondent 7 applied for the post, and interviews were conducted. Respondent 7 was ultimately selected and appointed, whereas the appellant was not selected.
Aggrieved thereby, the appellant challenged the selection process by filing a writ petition, contending that Respondent 7 did not possess a valid and updated OBC-NCL certificate in the prescribed format as on the cut-off date and had obtained such a certificate after the interview and selection process.
Aggrieved, the appellant challenged Respondent 7’s appointment. However, the Single Judge held that Respondent 7 had furnished a valid OBC-NCL certificate in terms of the Office Memorandum dated 8 October 2015, and therefore his selection and appointment as Associate Professor were valid.
The appellant thereafter preferred the present appeal assailing the Single Judge’s decision.
Issues, Analysis and Decision
The Court observed that Tripura University, being a Central University, was governed by the directives of the Government of India, including the Office Memorandums dated 8 October 2015 and 29 March 2023 issued by the DoPT regarding verification of claims of Scheduled Caste (SC), Scheduled Tribe (ST) and OBC candidates. The Court noted that these Office Memorandums permitted provisional consideration of a candidate’s claim based on prima facie proof and allowed submission of the prescribed caste certificate within a reasonable time.
The Court noted that the Office Memorandum dated 29 March 2023 states that,
“where a candidate belonging to SC, ST and OBC is unable to produce a certificate from any of the prescribed authorities, he/she may be appointed provisionally on the basis of whatever prima facie proof he/she is able to produce in support of his/her claim subject to his/her furnishing the prescribed certificate within a reasonable time and if there is genuine difficulty in his/her obtaining a certificate, the appointing authority should itself verify his/her claim through the District Authorities concerned”.
The Court considered the appellant’s reliance on Sakshi Arha v. Rajasthan High Court, 2025 SCC OnLine SC 757, and observed that, although the judgment dealt with OBC-NCL certificates and held that such certificate could not be produced beyond the cut-off date, it arose in the context of recruitment under the Rajasthan Judicial Service Rules, 2010. The Court held that the said decision had no application to the present case, where the Government of India Office Memorandums governed the field and permitted production of the caste certificate at a later date in spite of the advertisement saying that it should be produced before the cut-off date.
Accordingly, the Court did not agree with the appellant’s contention that Respondent 7’s appointment was liable to be set aside merely because the updated OBC-NCL certificate had not been produced before the cut-off date. The Court upheld the view taken by the Single Judge, and dismissed the appeal.
[Rajat Ghosh v. Tripura University, 2026 SCC OnLine Tri 197 decided on 14-5-2026]
*Judgment authored by Chief Justice M.S. Ramachandra Rao.
Advocates who appeared in this case :
For the appellant: Senior Advocate P. Roy Barman with Samarjit Bhattacharjee and Kawsik Nath, Dipjyoti Paul, Advocates
For the respondents: Senior Advocate B.P. Sahu with Suman Bhattacharjee, Kausik Paul, Uttara Singha, H. Kunjeshori Devi and Loha Liriina, Advocates
