Recruitment litigation ex facie may look deceptively trite: a candidate clears the written exam, appears in the merit list, and then loses out because of a “procedural” lapse: late document submission, a missed upload, or a delayed verification. The question courts repeatedly face is whether such lapses can be cured later, especially when the candidate appears meritorious and the default is explained by personal hardship.

In Smt. Aaradhna Buj v. State of Madhya Pradesh & Others, the High Court of Madhya Pradesh (Indore Bench) has held that in public recruitment, cut-off dates for document submission are not optional, and courts will not rewrite recruitment conditions to accommodate individual delays. There is no question of sympathy where recruitment rules and conditions are clear as daylight.

The case in brief

The petitioner applied under MPPSC Advertisement for the post of Assistant Professor. She appeared in the written examination held on 09.06.2024 and figured in the provisional merit list declared on 04.10.2024.

The result notice came with clear instructions: provisionally selected candidates had to submit required documents for verification on or before 25.10.2024, failing which the candidature would stand cancelled. MPPSC later granted extensions, first with late fee and finally with a substantial late fee, extending the last date up to 11.11.2024.

The petitioner still did not submit documents within time. She later made a representation citing illness (Mixed Connective Tissue Disease) as the reason for non-compliance. That representation was rejected, and she approached the High Court under Article 226 seeking acceptance of documents beyond the cut-off and consideration for appointment.

An interim order allowed her to participate in the interview subject to the final outcome, and her result was kept in sealed cover.

The real legal issue

This was not a dispute about marks, category, or eligibility in the academic sense. The core issue was narrow but important:

Can a writ court direct MPPSC to accept verification documents after the final cut-off date, on grounds of illness and equity, and thereby revive a cancelled candidature?

What the Court held

The High Court dismissed the petition. It held that:

1. the recruitment instructions were mandatory,
2. the petitioner failed to comply even after extensions, and
3. there was no legal basis to grant relaxation on medical/sympathetic grounds.

Why this judgment matters (and why it is worth reading)

1) Recruitment notices are not casual “guidelines”. They are binding on the candidates.

A key part of the Court’s reasoning comes from the “अन्य निर्देश” (Other Instructions/Directions) in the advertisement. These clauses place the responsibility squarely on the candidate to regularly check the Commission’s website for any updates, results, and instructions.

This matters because many candidates argue later that they “didn’t know” about the result or missed a link. The Court’s approach is strict: once you apply, you accept the system’s rules, including the duty of vigilance.

In practical terms, the Court treated the instructions as creating a binding obligation: the selection process cannot be run on individual claims of missed information.

2) The document submission clause was “self-executory”

The Court reproduced and relied upon the clause accompanying the result which stated, in substance:

• documents must reach by the last date,
• MPPSC is not responsible for postal delay,
• no correspondence would be entertained, and
• if documents do not reach, the candidate will be deemed unwilling and candidature will be cancelled.

The Court called this language mandatory and self-executory, meaning the consequence follows automatically once the deadline expires. There is no “second chance” unless the rules themselves provide it.

3) Extensions do not convert a deadline into a flexible concept

The petitioner argued that because MPPSC itself extended the deadline twice (with late fees), the cut-off could not be treated as rigid. The Court rejected this reasoning.

According to court, an extension only shifts the final cut-off, it does not destroy the concept of a cut-off.

In fact, the Court noted that the petitioner did not comply even within the extended windows.

4) Medical hardship is not a “relaxation clause”

The petitioner’s primary explanation was illness. The Court did not treat the illness claim as legally sufficient because:

• the advertisement/instructions did not provide any relaxation power on medical grounds, and
• recruitment to public posts must preserve equality and certainty.

This is a recurring theme in service jurisprudence: equity cannot override the rule of equal opportunity. If one candidate gets special indulgence, it risks discrimination against those who complied despite personal difficulties.

5) Interim orders don’t create permanent rights

Many litigants or Advocates may misunderstand interim protection. Being allowed to appear in an interview under a court’s interim order does not mean the court has “accepted” the case. It simply preserves a temporary position.

The High Court reaffirmed that participation due to interim order is at the candidate’s risk, and if the petition fails, the interim benefit collapses.

This point matters because candidates often argue, “I have already appeared, so now don’t deny me.” Courts may refuse that line, especially in recruitment matters. I suppose in recruitment matters it is hard to justify “public interest.”

The precedents the Court relied on

The judgment is heavily anchored in Supreme Court precedent on strict adherence to recruitment schedules.

Thahira P. v. Administrator, UT of Lakshadweep (2018) 6 SCC 446

The Court relied on this for the principle that timelines in selection processes must be adhered to, otherwise selection becomes uncertain and unmanageable.

Bedanga Talukdar v. Saifudaullah Khan (2011) 12 SCC 85

This is the backbone authority: recruitment conditions in the advertisement cannot be relaxed unless the power exists and is publicised; otherwise it violates Articles 14 and 16.

State of Rajasthan v. Hitendra Kumar Bhatt (1997) 6 SCC 574

Relied upon for two key points:

• interim order participation gives no vested right, and
• cut-off dates cannot be ignored for one individual because others may have been prejudiced.

The petitioner cited Vashist Narayan Kumar v. State of Bihar 2024 (1) MPLJ 328 to argue that minor technicalities should not defeat substantive rights. The High Court distinguished it, holding that the case cited by the petitioner involved a trivial clerical lapse, whereas in the present case the breach was of a mandatory cut-off timeline.

The legal takeaway

This decision can be cited for the following proposition:

Where a recruitment advertisement/result notice prescribes a mandatory last date for submission of verification documents with a clear consequence of cancellation, courts will not direct acceptance of documents beyond the cut-off on medical or sympathetic grounds, particularly after the recruitment process has concluded.

Conclusion

This case is important because it consolidates the approach courts increasingly follow: public recruitment cannot be run on ad hoc relaxations. The process must remain predictable and uniform for all candidates. For anyone dealing with MPPSC and similar recruitments, the judgment is a reminder that in service law, procedural timelines are not “mere technicalities”, that can be done away with.

Case Details

• Case Number: Writ Petition No. 39107 of 2024
• Neutral Citation: 2026:MPHC-IND:1944
• Court Name: High Court of Madhya Pradesh at Indore
• Bench: Single Bench
• Presiding Judge: Hon’ble Shri Justice Jai Kumar Pillai

FULL JUDGMENT CAN BE DOWNLOADED/READ AT MPHC.GOV.IN

Disclaimer

This post is for informational and educational purposes only. It does not constitute legal advice, financial advice, or professional advice of any kind. Laws and their interpretation may vary depending on facts, circumstances, and jurisdiction.

Neither Siddharth Shukla, Advocate, nor any associate, partner, or member of Siddharth Shukla Office, Jabalpur, accepts any responsibility or liability for any loss, damage, or consequence arising from reliance on this content.

Readers are strongly advised to consult a qualified lawyer or appropriate professional for advice specific to their situation. Reading this content does not create a lawyer–client relationship.