Chattisgarh High Court
Jyoti Rai vs State Of Chhattisgarh on 25 March, 2026
Author: Ramesh Sinha
Bench: Ramesh Sinha
1
Digitally signed
by ALOK
2026:CGHC:14177-DB
ALOK SHARMA
SHARMA Date:
2026.03.27
11:18:30 +0530 NAFR
HIGH COURT OF CHHATTISGARH AT BILASPUR
WA No. 250 of 2026
1 - Jyoti Rai W/o Chitrangad Lal Rai ( D/o Saheb Ram Bandey) Aged
About 41 Years R/o Village And Post Mohara Tahsil - Gurur, District -
Balod, Chhattisgarh.
... Appellant(s)
versus
1 - State Of Chhattisgarh Through Its Secretary, Department Of
Education, Mahanadi Bhawan, Mantralaya, New Raipur, District -
Raipur, Chhattisgarh.
2 - Director Directorate Of Public Instruction, Chhattisgarh Raipur
Indravati Bhawan, Naya Raipur, District - Raipur Chhattisgarh.
3 - Joint Director Education Division Bilaspur Chhattisgarh, District -
Bilaspur, Chhattisgarh.
... Respondent(s)
For Appellant(s) : Mr. Devashish Tiwari, along with Mr. Shiv Sewak, Advocate.
For Respondent/State : Mr. Shashank Thakur, Addl. Advocate General.
2Hon'ble Shri Ramesh Sinha, Chief Justice Hon'ble Shri Ravindra Kumar Agrawal, Judge Judgment on Board Per Ramesh Sinha, Chief Justice 25/03/2026 1 Heard Mr. Devashish Tiwari, appeared through video conferencing along with Mr. Shiv Sewak, learned counsel for the appellant as well as Mr. Shashank Thakur, learned Additional Advocate General, appearing for the Respondent/State on I.A. No. 1 of 2026, which is an application for condonation of delay of 18 days in filing the present appeal. 2 On due consideration, I.A. No. 1 of 2026 is allowed. Delay of 18 days in filing the present appeal is hereby condoned. 3 The present writ appeal has been filed by the writ appellant against the order dated 10.12.2025 passed by learned Single Judge in WPS No. 4617 of 2021. Thereafter, the writ appellant prefer the instant appeal before this Hon'ble Court with the following prayer:-
"a) Allow the present Writ Appeal;
b) Set aside and quash the Impugned Judgment dated 10.12.2025 passed by the learned Single Judge in Writ Petition (S) No. 4617 of 2021;
c) Set aside and quash the order dated 13.08.2021 (Annexure P1) passed by Respondent No. 3 rejecting the candidature of the Appellant;
d) Issue a writ of mandamus or any other appropriate writ, order or direction directing the Respondents to:
i) Accept the caste certificate dated 09.01.1996 issued by Naib Tehsildar as valid;
ii) Issue appointment letter to the Appellant for the post of English Teacher Category-T Cadre in pursuance of the offer of appointment dated 3 21.01.2021.
iii) Grant all consequential service benefits including seniority, salary, and arrears from the date appointment should have been issued;
e) Grant permission to the Appellant to file additional documents (Annexures A2, A3, A4, A5, and A6) which were not part of the record before the learned Single Judge;
f) Award costs of the present proceedings to the Appellant; AND/OR
g) Pass any other order(s) as this Hon'ble Court may deem fit and proper in the facts and circumstances of the case in the interest of justice, equity and good conscience."
4 The brief facts of the case are that the appellant, Jyoti Rai, belonging to the Scheduled Caste category, applied for the post of English Teacher (T-Cadre) pursuant to the recruitment advertisement issued in March 2019 by the Directorate of Public Instruction, Government of Chhattisgarh. Having successfully cleared the selection process, she was called for document verification on 21.01.2021, wherein her documents, including a caste certificate issued by the Naib Tehsildar (dated 09.01.1996), were duly scrutinized and found complete, and she was accordingly extended an offer of appointment. However, subsequently, by order dated 13.08.2021, her candidature was rejected on the ground that she had failed to produce a permanent caste certificate issued by the Sub-Divisional Officer (SDO), as required under the terms of the advertisement.
5 Aggrieved by the rejection, the appellant preferred Writ Petition (S) No. 4617 of 2021 before this Hon'ble Court; however, the same came to be dismissed by the learned Single Judge vide judgment dated 4 10.12.2025, holding that the appellant had failed to comply with Clauses 7 and 8 of the advertisement, as the requisite caste certificate from the competent authority was not produced at the time of verification, notwithstanding that the appellant subsequently obtained such certificate on 09.02.2022. The appellant contends that her original caste certificate was validly issued by a competent authority and had been accepted by the Respondents during verification, and that she was prevented from obtaining a fresh certificate earlier due to an administrative embargo, and therefore, the rejection of her candidature is arbitrary and unsustainable in law.
6 Learned counsel for the appellant submits that the impugned judgment dated 10.12.2025 is liable to be set aside as it suffers from patent illegality and non-application of mind. The learned Single Judge has erred in holding that the appellant's candidature was liable to be rejected for non-production of a caste certificate issued by the Sub- Divisional Officer, while completely ignoring that the caste certificate submitted by the appellant, issued by the Naib Tehsildar, was valid under the Madhya Pradesh Government Order dated 26.07.1984 and subsequent circulars, including the Ministry of Social Justice and Empowerment circular dated 19.01.2026, which recognize Naib Tehsildars as competent authorities to issue SC/ST certificates. The appellant's documents were duly verified and accepted by the Respondents on 21.01.2021, and an offer of appointment was extended, giving rise to legitimate expectation and attracting the doctrine of promissory estoppel. Further, the appellant was prevented 5 from obtaining a fresh certificate within the prescribed period due to an administrative embargo imposed between 2018 and 2022, which was beyond her control, and in any case, she subsequently obtained the requisite certificate, therefore, warranting interference by this Hon'ble Court in the interest of justice and impugned judgment is liable to be set aside.
7 Learned counsel for the respondent/State would submit that impugned judgment dated 10.12.2025 is entirely justified and requires no interference, as the appellant has failed to comply with the clear and unambiguous terms of the recruitment advertisement issued in March 2019. The advertisement explicitly mandated that all requisite documents, including minimum educational qualifications and caste certificates, must be submitted at the time of document verification and that certificates produced after the declaration of the result would not be considered. Clause 8 specifically required the production of a permanent caste certificate issued by the competent authority, namely the Sub-Divisional Officer, to avail the benefits of reservation and age relaxation. The appellant, having submitted only a certificate issued by the Naib Tehsildar and failing to produce the requisite SDO- issued certificate at the relevant time, did not fulfill the mandatory eligibility conditions stipulated in the advertisement. Consequently, the appellant was rightly denied the benefits of reservation and age relaxation, and the impugned order is in accordance with the terms of the advertisement and the law, and no interference by this Hon'ble Court is warranted.
68 We have heard learned counsel for the appellant and perused the impugned order and other documents appended with writ appeal. 9 After considering the submissions made by the learned counsel for the parties and upon perusal of the documents on record, the learned Single Judge came to the conclusion that:
"5. It is undisputed that the petitioner applied for the post of Teacher (English) under the SC category. The caste certificate submitted by the petitioner appears to have been issued by the Tahsildar sometime in the year 1994. Upon perusal of the conditions mentioned in the advertisement, it is evident that all the necessary qualifications and certificates including the permanent caste certificate were required to be obtained by the candidates on or before the date of declaration of the result by the examining authority. The permanent caste certificate must be issued by a competent authority otherwise the benefits of age relaxation or reservation would not be granted.
6. For ease of reference, paragraphs 7 and 8 of the advertisement are reproduced below:
"(7) अभ्यर्थी को आवश्यक न्यूनतम शैक्षणिक अर्हता एवं अन्य प्रमाण पत्र व्यापम द्वारा परीक्षा-फल जारी होने की तिथि अथवा उसके पूर्व प्राप्त करना अनिवार्य है। व्यापम द्वारा परीक्षा-फल जारी होने की तिथि के पश्चात् प्राप्त अर्हता प्रमाण पत्र मान्य नहीं होंगे।
(8) अभ्यर्थी को सक्षम प्राधिकारी द्वारा जारी स्थाई जाति प्रमाण पत्र प्रस्तुत करना होगा, अन्यथा विज्ञापन के तहत दर्शित छू ट (आयु/आरक्षण) का लाभ प्राप्त नहीं होगा।"
7. Although the caste certificate issued by the Naib Tahsildar was submitted by the petitioner, the 7 conditions mentioned in the advertisement clearly specify that a permanent caste certificate issued by a competent authority (le.. the Sub-Divisional Officer) was required. The petitioner has since obtained the permanent caste certificate from the SDO. However, the petitioner failed to comply with the conditions stipulated in Clauses 7 and 8 of the advertisement at the time of document verification. As a result, the petitioner is not entitled to the benefits of reservation or age relaxation, and this Court finds no illegality or irregularity in the impugned order.
8. In view of the above, and in light of the judgment of the Hon'ble Supreme Court in case of Sakshi Arha Vs. The Rajasthan High Court and ors. reported in 2025 LiveLaw (SC) 405, this writ petition is devoid of merit and is hereby dismissed. The interim order, if any, stands vacated."
10 Upon perusal of the impugned judgment of the learned Single Judge, it is evident that the dismissal of the writ petition is grounded on the clear terms of the recruitment advertisement, which mandated that all necessary qualifications and certificates, including the permanent caste certificate, must be obtained and produced by the candidates on or before the date of declaration of the result by the examining authority. The advertisement explicitly required that only a permanent caste certificate issued by a competent authority, namely the Sub-Divisional Officer, would entitle a candidate to the benefits of age relaxation and reservation. Although the petitioner had submitted a caste certificate issued by the Naib Tahsildar, the certificate did not meet the conditions prescribed under Clauses 7 and 8 of the advertisement at the time of 8 document verification. The petitioner's failure to comply with these mandatory requirements rendered her ineligible for the reserved post and the benefits attached thereto.
11 The learned Single Judge further relied on the binding principle laid down in the decision of the Hon'ble Supreme Court in Sakshi Arha v. The Rajasthan High Court (2025 LiveLaw (SC) 405), which underscores that compliance with eligibility conditions at the prescribed time is essential and cannot be waived on later submission of documents. The Court noted that the petitioner, despite subsequently obtaining a permanent caste certificate from the Sub-Divisional Officer, did not fulfill the advertisement's conditions at the relevant stage of verification, and therefore could not claim entitlement to reservation or age relaxation. In view of the above, the impugned order dismissing the writ petition is legally sound, and no interference is warranted, as the action of the authorities was in strict conformity with the terms of the advertisement and the law.
12 Thus, we are of the considered opinion that the learned Single Judge has not committed any illegality, irregularity or jurisdictional error in the impugned order warranting interference by this Court. 13 Accordingly, the writ appeal being devoid of merit is liable to be and is hereby dismissed. No cost(s).
Sd/- Sd/- S
Sd/-
(Ravindra Kumar Agrawal) (Ramesh Sinha)
Judge Chief Justice
Alok