India’s affirmative action policies provide for caste-based reservation in education, employment, and public services to ensure social justice and uplift historically marginalised communities. These provisions are embedded in the Constitution under Articles 15(4), 16(4), and other enabling clauses. However, the effectiveness and accessibility of these measures depend significantly on procedural compliance, particularly regarding the format of caste certificates submitted during recruitment or admission.
A recent landmark judgment of the Supreme Court in Mohit Kumar v. State of Uttar Pradesh (Civil Appeal No. 5233 of 2025) has reaffirmed the criticality of adhering strictly to prescribed formats for caste certificates while applying for reserved posts. The Court held that failure to submit a caste certificate in the correct State-prescribed format can lead to disqualification from availing reservation benefits, even if the applicant genuinely belongs to a backward category.
Background: Caste Certificate and Format Compliance
A caste certificate is an official document issued by a competent authority declaring that a person belongs to a specific Scheduled Caste (SC), Scheduled Tribe (ST), or Other Backward Class (OBC). To avail reservation benefits, candidates must submit this document in a format prescribed by the relevant recruiting or admitting authority—usually aligned with the state-specific or central government norms.
The prescribed format generally includes:
- Candidate’s caste/community name
- Certification by a competent authority (e.g., Tehsildar)
- A statement confirming non-creamy layer status (for OBCs)
- Affirmation of compliance with government notifications or criteria
While these requirements might appear technical, their purpose is to maintain consistency, verify eligibility, and prevent misuse of reservation quotas.
The Supreme Court’s Ruling in Mohit Kumar v. State of UP (2025)
In Mohit Kumar, the appellant had applied for the post of Sub-Inspector (Civil Police) in Uttar Pradesh under the OBC category. Although he submitted an OBC certificate, it was in the format prescribed for Central Government recruitments, not the State Government’s prescribed Format-I.
The Uttar Pradesh Police Recruitment and Promotion Board (UPPRPB) rejected his application under the OBC quota and treated him as a general category candidate. As a result, despite scoring more than the OBC cut-off (313.84 vs. 305.54), he was not selected due to failing the general cut-off (316.11).
Similarly, another candidate, Kiran Prajapati, was denied selection under the OBC category for failing to submit the certificate in the state-prescribed format.
The Supreme Court, upholding the UPPRPB’s decision, ruled that:
“Non-compliance with the terms of the advertisement/notification is bound to trigger adverse consequences… Clause 5.4(4) clearly warned about the consequence of failing to submit the requisite certificate in Format–I. Admittedly, the certificates submitted by Mohit and Kiran do not align with Format-I”
Key Legal Principles from the Judgment
1. Adherence to the Recruitment Notification is Mandatory
The Court held that once a recruitment notification is issued with clear instructions, compliance is not optional. Clause 5.4(4) of the notification explicitly stated that failure to submit a valid OBC certificate in the prescribed format would result in treatment as a general category candidate.
2. No Room for Relaxation in Clear-Cut Rules
The Court noted that there was no ambiguity in the requirement. Hence, there was no scope for leniency or flexible interpretation, unlike in cases where rules were silent or contradictory.
3. Format Ensures Verification of Creamy Layer Status
The State Government’s format required the candidate’s parental income and asset details, ensuring that only non-creamy layer candidates benefit from OBC reservation. The Central format lacked this level of scrutiny.
4. Precedents Do Not Override Specific Compliance
The Court distinguished this case from earlier instances where relief was granted, noting that those judgments were not binding precedents and were issued without detailed scrutiny at the admission stage.
Constitutional and Statutory Context
Article 16(4) of the Constitution
This provision enables the State to provide reservation in public employment for any backward class of citizens not adequately represented in services.
Uttar Pradesh Public Services (Reservation for SCs, STs, and OBCs) Act, 1994
This law mandates reservations in state services and authorises the government to issue rules and orders to implement such provisions. Format compliance is part of such regulatory mechanisms.
The Creamy Layer Principle
Introduced by the Supreme Court in Indra Sawhney v. Union of India (1992) Supp. (3) SCC 217, this principle excludes socially advanced individuals from the benefits of OBC reservation. Its application often varies between the Centre and States, necessitating separate formats.
Relevant Precedents
1. Registrar General, Calcutta High Court v. Shrinivas Prasad Shah (2013) 12 SCC 364
The Court upheld the rejection of a Scheduled Tribe claim due to failure to submit a certificate from the competent authority, reiterating that mere claim of belonging to a reserved category without prescribed documentation is insufficient
2. State of Tamil Nadu v. G. Hemalathaa (2020) 19 SCC 430
The Supreme Court refused to permit relaxation of eligibility criteria that were clearly prescribed, underscoring the importance of following recruitment rules strictly.
3. Dolly Chhanda v. Chairman, JEE (2005) 9 SCC 779
Though cited by the appellant for leniency, this case emphasised that the rule violation must not be fundamental to justify condonation, which did not apply in Mohit Kumar.
Arguments Against Format Rigidness
The petitioners argued that:
- They genuinely belonged to the OBC category.
- Certificates were issued by the same authority (Tehsildar).
- Non-selection due to format was arbitrary and detrimental to social justice.
- The State could have verified creamy layer status through an inquiry instead of rejecting applications outright.
While these contentions highlight substantive equality concerns, the Court found them insufficient to override the specific procedural mandate.
Implications of the Judgment
1. Heightened Awareness
Candidates and institutions must now pay heightened attention to procedural specifics in notifications. Ignorance or reliance on generic formats can result in irreversible consequences.
2. Uniformity in Certification Formats
There is a pressing need to harmonise formats across the Centre and States or issue clear conversion guidelines. Otherwise, genuine candidates may continue to suffer due to technical disqualification.
3. Burden on Recruiting Agencies
The judgment indirectly relieves recruiting agencies from having to investigate or clarify candidate eligibility post-application, reinforcing the principle that responsibility lies with the applicant.
4. Potential for Reform
The ruling may trigger policy discussions on whether format rigidity should be moderated in favour of substantive justice, particularly for rural and underprivileged aspirants.
Conclusion
The Supreme Court judgment in Mohit Kumar v. State of UP (2025) has set a decisive precedent on the importance of procedural compliance, especially format adherence for caste-based reservation.
It clarifies that claims of social status must be substantiated in the exact format prescribed, failing which aspirants may lose out on rightful opportunities.
While the judgment reinforces the sanctity of recruitment procedures, it also raises questions about balancing procedural stringency with the overarching goal of social justice.
Going forward, both aspirants and authorities must exercise utmost diligence—applicants must comply strictly with notification requirements, and policymakers must ensure that procedures do not inadvertently defeat the purpose of affirmative action.