Supreme Court Disqualifies Rajasthan APO Candidates Lacking Law Degree On Application Date

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The Court allowed the Rajasthan Public Service Commission’s appeal and held that eligibility for the Rajasthan Assistant Prosecution Officer Exam, 2024, had to be determined on the date of submission of the application, not on the date of examination or interview.

Supreme Court Allows RPSC Appeal

The Supreme Court on Monday, May 4, allowed the appeal filed by the Rajasthan Public Service Commission.

A Bench of Justice Vikram Nath and Justice Sandeep Mehta set aside the High Court judgment. The High Court had allowed certain candidates to appear in the Rajasthan Assistant Prosecution Officer Exam, 2024.

Justice Vikram Nath authored the judgment.

The Court held that candidates must possess the required qualification on the date they submit their application. Therefore, candidates who acquired a law degree later could not claim eligibility.

Candidates Acquired Law Degree After Applying

The dispute arose from a recruitment advertisement dated March 7, 2024.

Through this advertisement, the RPSC invited applications for 181 posts of Rajasthan Assistant Prosecution Officer.

The advertisement required candidates to hold a law degree. However, the respondent-candidates did not have the degree when they submitted their applications.

They acquired the qualification only on August 22, 2024. By that time, they had already applied for the post.

High Court Allowed Candidates To Appear

After RPSC denied them participation, the candidates approached the High Court.

Both the Single Bench and the Division Bench ruled in their favour. The High Court directed RPSC to issue admit cards to them for the preliminary examination.

Aggrieved by this direction, the RPSC approached the Supreme Court.

Eligibility Must Be Decided On Application Date

The Supreme Court held that the High Court erred in allowing the candidates to continue in the selection process.

The Court said the advertisement and the governing rules clearly fixed the relevant date for eligibility. That date was the date of submission of the application.

The Court noted that the recruitment authority assesses eligibility on the basis of documents submitted with the application.

Moreover, the rules did not allow candidates to submit fresh documents later to cure the defect.

Rules Did Not Permit Later Qualification

The Supreme Court also considered the Rajasthan Prosecution Subordinate Service Rules, 1978.

The Court found no provision that allowed final-year candidates to participate in the process.

Similarly, the rules did not permit candidates who acquired the qualification by the examination date to claim eligibility.

As a result, the Court held that candidates who lacked the law degree on the application date could not take part in the recruitment process.

Court Rejects Wider Competition Argument

The respondent-candidates argued that allowing more candidates would promote competition.

However, the Supreme Court rejected this submission.

The Court held that such considerations cannot override clear recruitment conditions. It said the advertisement allowed only one interpretation.

According to the Court, candidates had to possess the prescribed qualification on the date of application.

Later Qualification Cannot Cure Initial Ineligibility

The Supreme Court further observed that accepting the candidates’ argument would create uncertainty.

It said RPSC cannot be required to track qualifications acquired by candidates after submission of applications.

The Court also noted that such an approach would create an unnecessary administrative burden.

Accordingly, the Supreme Court allowed the appeal and restored the eligibility standard fixed by the advertisement and rules.

Case Details

Cause Title: Rajasthan Public Service Commission v. Lavanshu Sankhla & Ors. with connected matters
Citation: 2026 LiveLaw (SC) 455
Court: Supreme Court of India
Bench: Justice Vikram Nath and Justice Sandeep Mehta
Judgment Authored By: Justice Vikram Nath
Relevant Rules: Rajasthan Prosecution Subordinate Service Rules, 1978

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