Reserved Candidates Can Compete for General Seats if Rules Allow: Supreme Court

In CHAYA & ORS. ETC. v. THE STATE OF MAHARASHTRA & ANR. ETC., the Supreme Court clarified an important issue relating to reservation and merit in public employment. The Court held that reserved category candidates who avail relaxation can still be considered for general category posts if rules permit.

The ruling came from a Bench of Justices PS Narasimha and Alok Aradhe. The Court set aside the Bombay High Court’s Aurangabad Bench decision, which had denied such migration. The judgment emphasised that eligibility relaxation does not automatically restrict merit-based selection.

The dispute arose from teacher recruitment in Maharashtra under the Right to Education framework. Candidates had to clear the Teachers Eligibility Test (TET) and then appear for the Teachers Aptitude and Intelligence Test (TAIT), which determined final merit rankings.

General category candidates were required to secure 60% in TET, while reserved category candidates were given a 5% relaxation. Despite this, several reserved candidates scored higher marks than general category candidates in TAIT but were excluded from the open category list.

The Supreme Court held that such exclusion was unjustified. It was observed that the relevant Recruitment Rules did not prohibit migration to the general category. Therefore, denying meritorious candidates this opportunity lacked legal basis.

“The appellants who admittedly are more meritorious than the last selected candidate under the general category cannot be excluded from consideration under the general category, in the absence of any express prohibition in the Recruitment Rules/notification.”

The Court clarified that relaxation in qualifying exams only affects eligibility and not merit. It further noted that migration depends entirely on the applicable recruitment rules or notifications governing the selection process.

Referring to earlier cases like Union of India v. Sajib Roy (2025) and Union of India v. G. Kiran (2026), the Court highlighted that migration was denied in those cases due to explicit prohibitions. In contrast, no such restriction existed in the present matter.

The Court also distinguished Pradeep Kumar v. Government of NCT of Delhi (2019). It explained that the earlier case dealt with candidates failing to meet essential eligibility criteria, which was not the situation here.

Summarising the law, the Court laid down key principles. It stated that relaxation creates eligibility but does not dilute merit. Migration is permissible unless expressly barred, and candidates must still meet essential eligibility conditions.

Finally, the Court directed authorities to include the appellants in the merit list. It noted that the candidates had secured significantly higher marks than the last selected general category candidate, reinforcing the primacy of merit in final selection.