Recently, the Rajasthan High Court upheld the validity of a sports certificate issued by the Indian Body Builders Federation (IBBF) and affirmed the acceptance of a second application form submitted by a candidate for recruitment to the post of constable. The Court was dealing with a challenge to the respondent's selection on grounds of procedural and eligibility irregularities. Observing that IBBF is a recognized body by the Ministry of Youth Affairs and Sports, the Court held, “Once the body is recognized by the Government of India, there is no reason not to recognize the certificate issued by such a body.”
Brief Facts:
In this case, the Director General of Police, Rajasthan had initially issued an advertisement in 2019 inviting applications for constable posts. The respondent candidate applied under the sports quota but was initially rejected due to a deficiency in his sports certificate. Subsequently, an amended advertisement was issued in 2021, increasing the number of posts and re-inviting applications. Before the new deadline, the respondent participated in a national-level bodybuilding championship organized by the IBBF and secured third place. Based on this achievement, he submitted a fresh application form under the amended notification.
Contentions of the Appellant:
The appellant-petitioner challenged the respondent’s selection on two primary grounds. First, it was argued that the respondent's second application form should not have been accepted after his earlier application was rejected. Second, the petitioner contended that the IBBF was not among the recognized sports bodies listed under the original advertisement, and hence the certificate issued by it should not be considered valid for the purpose of recruitment.
Observations of the Court:
The Court thoroughly examined the recruitment notifications, the amended advertisement, and the relevant certificates. It found that the amended advertisement issued on 29.06.2021 had superseded the original, re-opening the application process and allowing all eligible candidates to reapply. The Court observed, “The earlier advertisement has for all purposes merged with the amended advertisement... Any person who was eligible as per the cut-off dates of the amended advertisement could have applied".
As to the validity of the sports certificate, the Court noted that the IBBF was duly recognized by the Ministry of Youth Affairs and Sports, Government of India, and by the All India Police Sports Control Board. This recognition, the Court emphasized, made the certificate fully valid under the revised terms of the recruitment.
Quoting from the judgment, the Court held, “When such associations/federations/bodies are duly recognised, then the certificate issued by them deserves to be considered... Once the body is recognized by the Ministry of Youth Affairs and Sports, Government of India and its recognition is duly renewed, there is no reason not to recognize the certificate issued by such a body/federation".
The Court also observed that the Selection Board had acted diligently by seeking clarification from the Indian Olympic Association and the Ministry before accepting the certificate. It concluded that no procedural or substantive irregularity had occurred in the selection process.
The decision of the Court:
Dismissing the appeal, the Division Bench concurred with the findings of the Single Judge, affirming that there was no illegality in the acceptance of the second application or in the recognition of the IBBF certificate. It held that the respondent was rightly awarded higher marks based on his national-level performance and was entitled to selection. The Court found no merit in the petition and refused to interfere with the selection.
Case Title: Garvit Vyas vs. State Of Rajasthan & Ors.
Case No: D.B. Spl. Appl. Writ No. 111/2025
Coram: Justice Kuldeep Mathur, Justice Baljinder Singh Sandhu
Advocate for Petitioner: Adv. Kamal Kishore Dave
Advocate for Respondent: Adv. B.L. Bhati, Manoj Bhandari (Sr. Advocate), Nes Gupta
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