No Right to Correct Online Application Errors Once Selection Process Commences: Delhi High Court

In an era where public recruitment has transitioned almost entirely to digital platforms, disputes arising from errors in online application forms have become increasingly common. Aspirants often approach courts seeking rectification of mistakes, invoking principles of fairness, proportionality, or bona fide error. However, courts have consistently drawn a firm line between trivial clerical mistakes and errors affecting eligibility.

Delhi High Court, in Nisha Khan v. Delhi Police & Anr., has reaffirmed this distinction and reiterated a strict but settled principle of service jurisprudence: once the selection process has commenced, candidates have no vested right to seek correction of errors in online applications that affect eligibility.

Factual Background of the Case

The controversy arose from the recruitment process for the post of Constable (Executive) Male/Female in Delhi Police, 2020, conducted through the Staff Selection Commission (SSC).

Key Facts

• The petitioner, Nisha Khan, applied online for the post within the prescribed time.
• The application form contained two relevant columns:
• Column 15: Whether the candidate is a departmental candidate of Delhi Police.
• Column 16: Whether the candidate is the son/daughter of serving, retired, or deceased Delhi Police personnel.
• Due to an alleged inadvertent error while filling the form at a cyber café, the petitioner marked:

“Yes” against Column 15, and

“No” against Column 16.

• In reality, the petitioner was the daughter of a serving Delhi Police officer and sought height relaxation, which was available only to the wards of police personnel.
• She qualified for the written examination and appeared for the Physical Endurance and Measurement Test (PEMT).
• At the time of PEMT, her height was found to be below the general category requirement but within the relaxed standard applicable to police wards.
• Initially, she was provisionally treated as eligible, but during data verification, the mismatch between her online declaration and documentary proof came to light.
• Her candidature was ultimately rejected because she had declared “No” under Column 16 in the online application.

Aggrieved, she approached the Central Administrative Tribunal (CAT), which dismissed her application. The matter then reached the Delhi High Court.

Issue

The principal issue for consideration was

• Whether a candidate can seek correction of errors in an online application form, affecting eligibility for relaxation, after the selection process has commenced, on the ground of bona fide mistake?

Submissions of the Petitioner

The petitioner advanced several arguments:

1. Bona fide clerical error: It was contended that the incorrect entries were unintentional and occurred due to reliance on cyber café assistance and technical glitches.
2. Production of original documents: The petitioner argued that she had produced all supporting documents during PEMT, including her father’s service certificate, and was initially found eligible.
3. Redundancy of Column 15: It was submitted that Column 15 was irrelevant since there could be no departmental candidates for the post of Constable.
4. Reliance on precedents: The petitioner relied on judgments where courts permitted correction of trivial or typographical mistakes, including:

Vashist Narayan Kumar v. State of Bihar

Ajay Kumar Mishra v. Union of India

Accordingly, she sought correction of the application form and restoration of her candidature.

Submissions of the Respondents

The respondents, including Delhi Police and SSC, opposed the petition by relying on:

Clear recruitment instructions

The examination notice explicitly stated that:

• Candidates must verify details before final submission.
• No correction or modification would be permitted after submission under any circumstances.

Candidate’s responsibility

• The onus of filling in accurate particulars lay entirely on the candidate.

Administrative impracticability

• Allowing post-submission corrections would open floodgates and disrupt a recruitment system catering to crores of applicants annually.

Settled law on recruitment conditions

• Courts cannot rewrite or dilute recruitment conditions once the process has commenced.

Findings of Delhi High Court

The Division Bench of Justice Navin Chawla and Justice Madhu Jain dismissed the writ petition and upheld the Tribunal’s order. The Court’s reasoning may be analysed under the following heads.

1. Sanctity of Recruitment Conditions

The Court reaffirmed that the terms of an advertisement are binding and cannot be diluted through judicial intervention unless they violate constitutional guarantees.

Relying on Supreme Court precedent, the Court held that when recruitment rules and advertisements are clear, courts cannot substitute their own notions of fairness in place of explicit conditions.

The prohibition on post-submission correction was neither ambiguous nor unreasonable and was uniformly applicable to all candidates.

2. Distinction Between Trivial Errors and Eligibility Errors

A critical aspect of the judgment lies in the Court’s distinction between:

• Trivial or typographical errors, and
• Errors going to the root of eligibility.

The Court observed that earlier judgments allowing corrections typically involved mistakes such as minor discrepancies in date of birth that did not alter eligibility.

In contrast, the petitioner’s incorrect declaration directly impacted her entitlement to height relaxation, which was fundamental to her eligibility. Such an error could not be treated as inconsequential.

3. No Right to Rectification After Failure

The Court made an important observation with far-reaching consequences:

A candidate cannot be permitted to seek correction of particulars only after discovering that the mistake has resulted in disqualification.

Allowing such claims would be unfair to other candidates who may have made similar errors but did not approach the courts.

4. Equality and Level Playing Field

Granting relief to one candidate would violate Article 14 by introducing unequal treatment among similarly placed aspirants.

The Court emphasised that recruitment processes must operate on uniform standards, and individual hardship cannot override systemic fairness.

5. Rejection of “Redundant Column” Argument

The argument that Column 15 was redundant was categorically rejected. The Court held that:

• The relevance of any field in an application form is for the recruiting authority to decide.
• A candidate who participates in the process cannot later challenge the utility of application fields.

6. Limited Scope of Judicial Review in Recruitment Matters

Reiterating settled law, the Court held that judicial review does not extend to rewriting recruitment conditions or granting equitable relief contrary to explicit rules.

The role of the Court is confined to examining illegality, arbitrariness, or constitutional violations—none of which were present in this case.

Policy Perspective: Digital Governance and Accountability

The decision also reflects broader policy concerns in digital governance:

• Online recruitment involves massive scale and automation.
• Allowing discretionary corrections would compromise efficiency and fairness.
• Candidates are expected to adapt to digital accountability standards.

The judgment implicitly encourages digital literacy and personal responsibility in public employment processes.

Conclusion

Delhi High Court’s decision in Nisha Khan v. Delhi Police & Anr. decisively settles that there is no vested or equitable right to correct online application errors once the selection process has commenced, particularly when such errors affect eligibility.

By drawing a clear line between trivial clerical mistakes and substantive eligibility-related errors, the Court has reinforced the principles of certainty, equality, and administrative efficiency in public recruitment.

The ruling serves as a cautionary precedent for aspirants and a stabilising assurance for recruiting authorities that clearly framed recruitment rules will be upheld, even in the face of individual hardship. Ultimately, the judgment underscores a fundamental truth of service law: procedural discipline is not the enemy of fairness; it is its foundation.

Important Link

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