Reserved Category Candidates Eligible for General Seats on Merit: Supreme Court Clarifies

In a significant judgment delivered in Chaya & Ors. v. State of Maharashtra & Anr. (2026), the Supreme Court of India clarified a recurring and contentious issue in public employment law, whether candidates belonging to reserved categories who avail relaxation in qualifying examinations can still be considered for selection in the general (open) category based on merit.

The ruling reaffirms the principle that merit remains the cornerstone of public employment, and that relaxation in eligibility criteria does not necessarily disentitle a candidate from competing in the open category, unless expressly prohibited by recruitment rules.

This judgment is particularly relevant in the context of teacher recruitment processes across India and contributes to the evolving jurisprudence on reservation, equality, and merit under Articles 14 and 16 of the Constitution.

Background of the Case

The case arose out of recruitment to teaching posts in Maharashtra through the Teachers Aptitude and Intelligence Test (TAIT), 2022, conducted by the Maharashtra State Council for Education (MSCE).

The appellants belonged to reserved categories and had qualified for the Teacher Eligibility Test (TET) by availing a relaxation of 5% in qualifying marks, as permitted under state policy. However, in the subsequent TAIT examination, they secured marks higher than several candidates selected under the general category.

Despite their superior performance, their names were excluded from the general merit list because they had availed relaxation in TET. The High Court upheld this exclusion, relying on earlier precedents.

Aggrieved, the candidates approached the Supreme Court.

Issue

• Whether reserved category candidates who have availed relaxation in a qualifying examination can be considered for general category seats if they secure a higher merit in the main selection process?

Statutory and Regulatory Framework

The recruitment process was governed by the following:

• Right of Children to Free and Compulsory Education Act, 2009
• NCTE Guidelines (2011) prescribe TET as a mandatory qualification
• Maharashtra Government Resolutions (2013, 2017, 2019)
• TAIT-based selection system

Under these rules:

• TET is a qualifying (eligibility) examination
• General category candidates must score 60%
• Reserved category candidates may qualify with 55% (5% relaxation)

The final selection, however, was based entirely on TAIT scores, not TET.

Arguments by the Parties

Appellants (Reserved Category Candidates)

• Relaxation in TET only affects eligibility, not merit.
• The open category is a merit-based category, not reserved for general candidates.
• Denying them general category seats despite higher marks violates Article 14 and Article 16.
• Reliance on earlier cases like Jitendra Kumar Singh and Vikas Sankhala.

Respondents (State Authorities)

• Candidates who availed relaxation should remain within their reserved category.
• Allowing migration would result in double benefit of reservation.
• Relied on Pradeep Kumar v. Govt. of NCT Delhi (2019).

Supreme Court’s Analysis

The Court undertook a detailed examination of prior precedents and clarified the distinction between:

1. Eligibility vs Merit

The Court emphasised that:

• Relaxation in TET is only to enable participation in the selection process.
• It does not influence the merit determined in the main examination.

“Relaxation in qualifying criteria only affects eligibility and not merit.”

Thus, once candidates enter the selection process, all compete on equal footing.

2. Concept of “Level Playing Field”

The Court reiterated that:

• Relaxations are tools of substantive equality
• They merely bring disadvantaged candidates into the zone of consideration
• Final selection must be based purely on performance

This aligns with the constitutional vision under Articles 14, 15, and 16.

3. Open Category is Not Reserved for General Candidates

A crucial clarification made by the Court:

• The open category is not synonymous with general category
• It is a merit-based pool open to all candidates, irrespective of caste

Thus, a reserved category candidate who performs better than general candidates must be placed in the open category.

4. Role of Recruitment Rules

The Court laid down a key principle:

Migration depends on the recruitment rules or notification

If rules:

• Permit migration → Allowed
• Are silent → Allowed
• Expressly prohibit → Not allowed

In this case, there was no prohibition.

5. Distinguishing Earlier Judgments

The Court clarified the applicability of previous rulings:

(i) Government of (NCT of Delhi) & Ors. v. Pradeep Kumar & Ors. (2019)

Not applicable because candidates there did not meet the essential eligibility criteria

(ii) Jitendra Kumar Singh v. State of U.P. (2010)

Held that concessions only enable participation, not advantage

(iii) Vikas Sankhala & Ors. v. Vikas Kumar Agarwal & Ors. (2017)

Allowed migration where merit is unaffected

The Court held that these latter judgments were more relevant to the present case.

Key Legal Principles Laid Down

The Supreme Court summarised the law as follows:

1. Relaxation in eligibility does not affect merit.
2. Such relaxation only creates a level playing field.
3. Candidates must meet minimum eligibility requirements.
4. Migration depends on recruitment rules.
5. In the absence of prohibition, migration is permissible.

Application to the Present Case

Applying these principles, the Court found:

• TET relaxation was legally permitted.
• It only enabled candidates to appear in TAIT.
• Final merit was based solely on TAIT scores.
• No relaxation was given in TAIT.
• Recruitment rules did not prohibit migration.

Therefore:

Candidates who scored higher than general category candidates must be included in the open category

Final Judgment

The Supreme Court:

• Set aside the High Court judgment
• Directed inclusion of appellants in the general merit list
• Allowed all appeals

Conclusion

The Supreme Court’s ruling in Chaya v. State of Maharashtra marks a significant development in Indian service law. It reaffirms that reservation is a means to achieve equality, not a barrier to merit.

By holding that relaxation in qualifying examinations does not bar migration to the open category, unless explicitly prohibited, the Court has reinforced the principle that the open category is a merit-based domain accessible to all candidates.

This judgment ensures that deserving candidates are not penalised for availing constitutionally sanctioned relaxations and that the ultimate determinant of selection remains merit. It also serves as a guiding precedent for future recruitment processes, emphasising clarity in rules and fairness in implementation.

Important Link

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