Eligibility for public employment must be satisfied on the last date of application unless rules provide otherwise
Facts
The Rajasthan Public Service Commission (RPSC) issued an advertisement dated 07.03.2024 for recruitment to 181 posts of Assistant Prosecution Officer, requiring a Law Degree as an essential qualification.
The respondents applied despite not having completed their LL.B. degree on the last date of application. They obtained the degree later (22.08.2024), before the preliminary examination (19.01.2025).
Subsequent press notes clarified that only candidates possessing the qualification on the last date of application were eligible.
The High Court allowed candidates to appear in the exam, reasoning that qualification obtained before the exam should suffice. RPSC appealed.
Issues Framed
Whether the relevant date for determining eligibility (educational qualification) is the date of application or a later stage such as examination/interview.
Court’s Reasoning
(a) The Court held that eligibility must be determined based on the date of submission of application, as the recruitment process evaluates candidates on the basis of information furnished at that stage (Para 18).
(b) A conjoint reading of the advertisement and governing rules showed that candidates must “possess” the qualification—indicating present possession, not future acquisition (Para 21).
(c) The earlier proviso allowing final-year candidates had been deleted from the Rajasthan Prosecution Subordinate Service Rules, 1978, reflecting clear legislative intent to exclude such candidates (Para 20).
(d) The Court applied the principle “what cannot be done directly cannot be done indirectly”, holding that allowing later acquisition would defeat the rule (Para 21).
(e) The High Court erred in adopting a liberal interpretation to enlarge the pool of candidates; where language is clear, equity or fairness cannot override statutory rules (Para 23).
(f) Allowing later qualification would create uncertainty and administrative difficulty in tracking eligibility (Para 24).
Held
Only candidates possessing the required qualification as on the last date of application are eligible. The High Court judgment was set aside and appeals allowed.
Ratio
In recruitment governed by statutory rules, eligibility conditions—especially educational qualifications—must be satisfied on the last date of application, and cannot be relaxed by later acquisition unless expressly permitted .
Case Details
Citation: 2026 INSC 444
Decided on: 4 May 2026
Case Title: Rajasthan Public Service Commission v. Lavanshu Sankhla & Ors.
Court: Supreme Court of India
Bench: Vikram Nath, J.; Sandeep Mehta, J.