Poonam Dwivedi & Ors. v. State of U.P. & Ors.

 EWS certificate must strictly correspond to the prescribed financial year prior to application; certificates of a different or incomplete financial year render candidates ineligible.

Facts

Recruitment under EWS quota rejected due to defective certificates

(a) The U.P. Subordinate Service Selection Commission issued an advertisement dated 15.12.2021 for 9212 posts of Health Worker (Female), reserving 10% for EWS candidates (Para 3–4).

(b) Clause 8.3 required submission of an EWS certificate in prescribed format issued before the last date of application (05.01.2022) (Para 5).

(c) The prescribed form mandated disclosure of income and assets for a specific financial year (Para 6).

(d) Appellants submitted certificates which were either:

  • issued before completion of FY 2020–21,
  • related to wrong financial year, or
  • reflected incorrect income period (Paras 7–8).

(e) Their candidature under EWS was rejected; they failed in general category cut-off (Para 10).

(f) The Single Judge granted relief citing confusion; Division Bench reversed; matter reached Supreme Court (Paras 12–16).

Issues Framed

Whether the EWS certificates submitted by the appellants were valid for claiming reservation under the advertisement (Para 18).

Court’s Reasoning

(a) Legal Requirement
The Court held that EWS eligibility depends on income of the “financial year prior to the year of application” (Para 23–24), under:

  • Section 7, U.P. Public Services (Reservation for Economically Weaker Sections) Act, 2020
  • Government O.M. dated 18.02.2019

(b) Interpretation of Advertisement
The certificate must:

  • exist before the cut-off date, and
  • relate to the correct financial year (2020–21) (Para 20–21).

(c) Application to Facts
The Court found:

  • Certificates issued in Jan–Feb 2021 could not validly relate to FY 2020–21 as the year had not ended (Para 25).
  • Certificates relating to other years (e.g., 2019–20 or 2021–22) were fundamentally defective (Para 25–26).

(d) Eligibility is Substantive, Not Procedural
Relying on UPSC v. Gaurav Singh and Divya v. Union of India, the Court held that:
“certificate of a different financial year goes to the root of the eligibility” (Para 26–27).

(e) Rejection of Equity Argument
The plea that errors were due to State authorities was rejected:
candidates could have obtained fresh certificates after advertisement (Para 26).

(f) Administrative Practicality
The Court emphasized that in mass recruitment, automated scrutiny necessitates strict compliance; otherwise, the process is disrupted (Para 28).

Held

Appeals dismissed; rejection of EWS claims upheld as certificates were invalid (Para 29).

Ratio

An EWS certificate must, by the cut-off date, strictly correspond to the prescribed format and the financial year prior to the year of application, failing which the candidate is ineligible for reservation.

Case Details

Citation: 2026 INSC 351
Decided on: 10 April 2026
Case Title: Poonam Dwivedi & Ors. v. State of U.P. & Ors.
Court: Supreme Court of India
Bench: Manoj Misra, J.; Prasanna B. Varale, J.


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