[Cites 4, Cited by 0]
Madhya Pradesh High Court
Pooja Prajapati vs The State Of Madhya Pradesh on 15 December, 2025
NEUTRAL CITATION NO. 2025:MPHC-IND:36975
1 WP-45941-2025
IN THE HIGH COURT OF MADHYA PRADESH
AT INDORE
BEFORE
HON'BLE SHRI JUSTICE JAI KUMAR PILLAI
ON THE 15th OF DECEMBER, 2025
WRIT PETITION No. 45941 of 2025
POOJA PRAJAPATI AND OTHERS
Versus
THE STATE OF MADHYA PRADESH AND OTHERS
Appearance:
Mr. Akash Sharma, counsel for the petitioners.
Mr. Amit Bhatia, counsel for the respondents/State.
ORDER
This writ petition has been preferred by the petitioners' under Article 226 of the
Constitution of India, seeking a direction to the respondents to consider the candidature
of the petitioner in General Diploma Category instead of Special Diploma Category.
2. It is the case of the petitioners' that the petitioners are the residents of Madhya
Pradesh, and are the citizens of India, and is therefore amenable to the writ jurisdiction
of this Hon'ble Court. The petitioners' had appeared in the Primary School Teacher
Recruitment Examination, 2020, conducted by Respondent No.2, and successfully
qualified the same by securing marks above the prescribed cut-off. Thereafter, the
respondents introduced a subsequent recruitment process by framing a new set of rules,
wherein an additional examination was prescribed along with revised eligibility
criteria, creating two distinct categories of candidates, namely General Diploma
Holders (D.El.Ed) and Special Diploma Holders (Special D.El.Ed), the latter being
applicable to specially abled candidates. In compliance with the said rules, the
petitioners appeared in the recruitment examination conducted in the year 2025;
however, while submitting the online application form, owing to a bonafide human
error on the part of the operator of the M.P. Online portal, the option pertaining to the
Special D.El.Ed category was inadvertently selected instead of the General D.El.Ed
category.
NEUTRAL CITATION NO. 2025:MPHC-IND:36975
2 WP-45941-2025
3. It is further stated by the petitioners' that they appeared in the aforesaid
examination and secured qualifying marks, as displayed on the computer screen upon
completion of the examination, which constitutes a sufficiently meritorious score for
consideration for final selection to the post. It has been contended by the petitioners
that the petitioners became aware of the said inadvertent error only upon subsequent
scrutiny of the application form, whereupon they promptly submitted several
representations and emails to the respondents requesting that their candidature be
considered under the General D.El.Ed category. It is respectfully submitted that the
only distinction between the Special D.El.Ed and General D.El.Ed categories under the
rules is the grant of five bonus marks to candidates of the Special D.El.Ed category,
whereas the petitioners possesses a valid General D.El.Ed qualification along with the
requisite teaching experience, and even without the grant of such bonus marks, his
score remains sufficient to warrant selection. Owing to the inaction on the part of the
respondents and in view of the imminent declaration of the examination results, the
petitioners have been constrained to invoke the extraordinary jurisdiction of this
Hon'ble Court, asserting that he is fully qualified, competent, and desirous of
appointment to the post, and that he cannot be made to suffer adverse consequences for
an error attributable solely to a third party, namely the M.P. Online portal operator,
particularly when they have been awaiting such opportunity since having qualified the
examination held in the year 2020.
4 . The counsel for the petitioners' submitted that rejection of the petitioners'
candidature on account of the inadvertent option of "Special D.El.Ed" column instead
of "General Diploma" would be manifestly arbitrary, capricious, unreasonable, and
grossly disproportionate to the alleged lapse, thereby violating Article 14 of the
Constitution of India. It was contended that the error was trivial, bona fide, non-
material, and purely inadvertent, conferring no advantage whatsoever upon the
petitioner and having no bearing on her eligibility for the post. Reliance was placed on
judicial precedents, including Manjana v. State of H.P. & Ors. and Vashist Narayan
Kumar v. State of Bihar & Ors. , wherein it has been consistently held that candidature
cannot be rejected for minor or trivial errors which do not amount to misrepresentation
or suppression of material facts, particularly after participation in and clearance of
NEUTRAL CITATION NO. 2025:MPHC-IND:36975
3 WP-45941-2025
stages of the selection process, as the law does not concern itself with trifles.
5. The counsel for the petitioners' further submitted that the petitioners never
concealed or suppressed any material information, nor indulged in any fraudulent
conduct, and duly submitted all requisite documents evidencing possession of the
prescribed General Diploma qualification as per the applicable rules for the Primary
School Teacher Examination, 2025. It was argued that the petitioners had a legitimate
expectation to be considered for selection, forming an integral facet of Article 14 of the
Constitution, and that permitting consideration under the correct category would cause
no prejudice to any other candidate, would not disturb any merit list, nor compromise
the integrity of the selection process. Accordingly, directions were sought to treat the
wrong selection as a clerical or inadvertent error, to consider the petitioners' under the
General Diploma Holder category, to permit participation in the further selection
process, and to grant any other relief deemed fit in the facts and circumstances of the
case.
6. Heard counsel for the parties and perused the record.
7 . This Court is of the view that the petitioners' had qualified the Primary School
Teacher Recruitment Examination, 2020 conducted by Respondent No. 2 and, pursuant
to the subsequent recruitment rules, appeared in the Primary School Teacher
Recruitment Examination, 2025. While submitting the online application form, the
petitioners, due to a bonafide clerical error attributable to the M.P. Online portal
operator, was inadvertently shown under the Special D.El.Ed category instead of the
General D.El.Ed category, despite possessing and uploading documents relating to the
General D.El.Ed qualification. The petitioners' secured qualifying marks in the
examination, which is otherwise sufficient for consideration, and no benefit of the
Special D.El.Ed category was claimed or derived.
8. This Court finds that the error in question is purely inadvertent, non-material, and
does not go to the root of eligibility. There is no allegation of misrepresentation,
suppression, or fraud on the part of the petitioners. Rejection of the petitioners'
candidature on such a technical lapse would be manifestly arbitrary, unreasonable, and
disproportionate, offending the guarantee of equality under Article 14 of the
NEUTRAL CITATION NO. 2025:MPHC-IND:36975
4 WP-45941-2025
Constitution. The settled legal position is that trivial mistakes not affecting eligibility
cannot be made a ground to deny consideration after participation in the selection
process.
9. This Court further holds that the grievance raised is not individual in nature but
affects similarly situated candidates who may have inadvertently opted for an incorrect
D.El.Ed category while being otherwise eligible. Accordingly, the present judgment
shall operate as a judgment in rem. Respondent No. 2/Selection Board is directed to
issue a corrigendum within seven (07) days from the date of receipt of certified copy of
the order, providing an online correction window of fifteen (15) working days to enable
all such candidates to rectify their category strictly in accordance with their eligibility.
The said facility shall be a one-time measure and shall not be extended beyond the
stipulated period and shall not be a precedent.
10. In view of the above, the writ petition is allowed. The petitioners' candidature
shall be considered under the General D.El.Ed category for all consequential purposes.
The benefit of this judgment shall extend to all similarly situated candidates, including
those who have even not approached this Court.
No order as to costs.
(JAI KUMAR PILLAI)
JUDGE
Arun/-
