Raju Mahto v. Union Of India & ORS.

$~76 * IN THE HIGH COURT OF DELHI AT NEW DELHI + W.P.(C) 1401/2026 & CM APPL. 6872/2026 RAJU MAHTO .....Petitioner Through:

Mr. Alok Raj, Advocate.

versus UNION OF INDIA & ORS.

.....Respondents Through:

Mr. Sahaj Garg, SPC with Mr.

Deepansh Sharma, G.P. for R-1.

CORAM:

HON'BLE MR. JUSTICE SANJEEV NARULA

O R D E R

% 02.02.2026 1.

The Petitioner, a visually impaired (blind) person, is presently employed as a Junior Clerk with the East Central Railway, Dhanbad Division. He applied for recruitment to the post of Probationary Officers/Management Trainees for the vacancies pertaining to the year 2026-27.

2.

The recruitment notification provided for reservation in favour of candidates belonging to the Other Backward Classes ('OBC') as well as Persons with Disabilities ('PwD'). The Petitioner applied under the OBC (Non-Creamy Layer) category and also claimed the benefit of reservation as a visually impaired candidate. He appeared in the preliminary as well as the main examination, cleared both stages, and secured marks above the prescribed cut-off. Consequently, he was called for interview. 3.

At the stage of interview, the Petitioner was required to furnish a valid W.P.(C) 1401/2026 Page 1 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

OBC (Non-Creamy Layer) certificate. However, since he relied upon an OBC certificate dated 22nd August, 2022 and did not produce a certificate issued within the period prescribed under the recruitment notification, he was not permitted to participate in the interview on the ground that the certificate relied upon by him had expired.

4.

It is in this background that the Petitioner has approached this Court, seeking the following reliefs:

"Issue a writ of Mandamus or Any Other Appropriate Writ(s), Order(s) or Direction(s) directing the Respondent No. 3 to conduct the interview of the Petitioner for CRP PO/MT-XV Common Recruitment Process for recruitment of Probationary Officers/Management Trainees for vacancies of 2026-27 and consider his candidature on merits"

5.

Mr. Alok Raj, counsel for the Petitioner, submits that the Petitioner had secured marks in the main examination above the cut-off prescribed even for the unreserved category. It is contended that the Petitioner fulfils all substantive eligibility criteria and genuinely belongs to the OBC (NonCreamy Layer) category. Being a visually impaired candidate, denial of participation in the interview on account of non-production of a contemporaneous OBC certificate is arbitrary and violative of Article 16 of the Constitution of India.

6.

It is urged that the Petitioner was unaware that the OBC certificate dated 22nd August, 2022 was valid only for a period of one year, and came to know of this requirement only with the assistance of a friend. The Respondents have adopted a mechanical and unfair approach in denying him the opportunity to appear in the interview.

7.

Mr. Raj further submits that even prior to the date of interview, the W.P.(C) 1401/2026 Page 2 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

Petitioner had applied for issuance of an income certificate, which is a prerequisite for issuance of an OBC (Non-Creamy Layer) certificate. The application in this regard was submitted before the concerned SubDivisional Magistrate on 13th December, 2025. However, since the income certificate could not be issued before the date of interview, the consequential delay occurred. It is stated that the Petitioner has since obtained the requisite OBC (Non-Creamy Layer) certificate and, therefore, a writ of mandamus ought to be issued directing the Respondents to conduct his interview and consider his candidature on merits for the post of Probationary Officers/Management Trainees for the vacancies of 2026-27. 8.

The Court has considered the aforesaid submissions. Undoubtedly, the Petitioner cleared both the preliminary and main examinations, which reflects merit in his candidature. The Court also has sympathy for the Petitioner, particularly keeping in view his disability. However, sympathy cannot override the binding conditions of the recruitment process, and the Court must act within the confines of law.

9.

The recruitment notification specifically stipulated the requirement of submission of a valid OBC (Non-Creamy Layer) certificate. The relevant condition reads as under:

"(v) In case of candidates belonging to OBC category, certificate should specifically contain a clause that the candidate does not belong to creamy layer section excluded from the benefits of reservation for Other Backward Classes in Civil post & services under Government of India. Candidates belonging to OBC category but coming under creamy layer are not entitled to OBC reservation. They should indicate their category as General in the online application form. The candidate should possess a valid OBC certificate with a Non-creamy layer clause as per the Government of India guidelines, from time to time. OBC category candidates should submit the OBC certificate on the format prescribed by Govt. of India containing the W.P.(C) 1401/2026 Page 3 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

'non-creamy layer' clause, issued on or after 01.04.2025 till the date of interview. The candidate should be in possession of requisite OBC (NCL) certificate in the prescribed format in support of his / her claim for availing reservation on / or before the date of Interview."

[Emphasis Supplied] 10.

It is not in dispute that the recruitment notification required the candidate to be in possession of, and produce, the requisite OBC (NonCreamy Layer) certificate on or before the date of interview for the purposes of document verification. The general instructions accompanying the notification further made it clear that a candidate's admission to various stages of the selection process was strictly provisional, and that candidature could be rejected at any stage upon failure to fulfil eligibility norms or upon non-production of requisite documents. The relevant portion is as follows: "N.

GENERAL INSTRUCTIONS

(1) Candidates will have to invariably produce the requisite documents such as valid call letter, a photocopy and original of photo-identity proof bearing the same name as it appears on the online submitted application form etc. at the time of online examinations (Preliminary & Main) and interview respectively. No document shall be directly sent to IBPS by the candidates before or after online examinations and interview. xx........xx........xx.........

(7) A Candidate's admission to the Online Preliminary and Main examinations/ shortlisting for interview/ and subsequent processes is strictly provisional. The mere fact that the call letter(s)/provisional allotment has been issued to the candidate does not imply that his/her candidature has been finally cleared by IBPS/ Participating Banks. IBPS/ Participating Banks would be free to reject any application, at any stage of the selection process, cancel the candidature of the candidate in case it is detected at any stage that a candidate does not fulfill the eligibility norms and/or that he/she has furnished any incorrect/false information/certificate/documents or has suppressed any material fact(s). If candidature of any candidate is rejected for any reason according to the terms and conditions of this notification, no further representation in this regard will be entertained. Such decisions shall be final and binding on the candidate. If any of these shortcomings is/are detected after appointment in a Participating Bank, his/her services are liable to be summarily terminated.

W.P.(C) 1401/2026 Page 4 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

(8) Decision of Nodal Banks/Participating Banks/ IBPS in all matters regarding eligibility of the candidate, the stages at which such scrutiny of eligibility is to be undertaken, qualifications and other eligibility norms, the documents to be produced for the purpose of the conduct of Examination, interview, verification etc. and any other matter relating to CRP-PO/MT-XV will be final and binding on the candidate. No correspondence or personal enquiries shall be entertained by IBPS/Participating Banks in this regard. IBPS/Nodal Bank/Participating Banks take no responsibility to receive/ collect any certificate/remittance/ document sent separately."

[Emphasis Supplied] 11.

In view of above, the Petitioner cannot therefore be permitted to contend that he was unaware of the requirement of possessing a valid OBC (Non-Creamy Layer) certificate issued within the prescribed period. The OBC certificate dated 22nd August, 2022, relied upon by the Petitioner, was clearly not valid for the purpose of the recruitment in question, since such certificates are required to be issued on a year-to-year basis, and the notification mandated issuance on or after 1st April, 2025. It is also a matter of record that the Petitioner applied for issuance of the income certificate only on 13th December, 2025, whereas the interview was scheduled on 16th December, 2025. In such circumstances, the failure to obtain the requisite OBC (Non-Creamy Layer) certificate prior to the date of interview cannot be attributed to the Respondents.

12.

Furthermore, the selection process has since been completed, the final result has been declared, and the select list has been prepared. Entertaining the present petition, at this stage, would amount to unsettling the concluded selection process, at least insofar as the post and category for which the Petitioner had applied are concerned.

13.

In view of the foregoing discussion, this Court is not inclined to entertain the present petition.

W.P.(C) 1401/2026 Page 5 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.

14.

The writ petition is accordingly dismissed, along with the pending application.

SANJEEV NARULA, J FEBRUARY 2, 2026 as W.P.(C) 1401/2026 Page 6 of 6 The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above.