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Apex Digest/Chaya & Ors. v. State of Maharashtra & Anr.
Supreme Court of India

Chaya & Ors. v. State of Maharashtra & Anr.

(2026) INSC 277 | Civil Appeal Nos. of 2026 (@SLP(C) Nos. 14517–14539 of 2025)

Decided: 23 March 2026
Justice P.S. Narasimha & Justice Alok Aradhe
ReservationMerit MigrationOpen CategoryTET RelaxationTeacher RecruitmentTAIT ExaminationEligibility vs MeritArticle 16Recruitment RulesService Jurisprudence

Key Issue / Question of Law

A. Whether candidates who availed relaxation in a qualifying exam (TET) can migrate to the open category based on merit in the main exam (TAIT)? B. Whether reliance on Pradeep Kumar (2019) to deny such migration was legally correct?

Ratio Decidendi

Relaxation in qualifying examinations affects only eligibility and not merit. Migration to the open category is permissible where Recruitment Rules do not expressly prohibit it.

Holding / Decision

A. Appeals ALLOWED B. Appellants entitled to migration to open category based on merit

Full Analysis

Practical Implications for Advocates

This judgment fundamentally reshapes how advocates approach reservation and migration disputes in public employment. It establishes that the decisive factor is not whether a candidate availed relaxation at the eligibility stage, but whether the Recruitment Rules expressly prohibit migration. In practice, this means that before drafting any writ petition or defence, advocates must first scrutinise the recruitment notification and governing rules—this becomes the primary document, not case law. For petitioners, the strategy is to demonstrate that relaxation was confined to the qualifying stage and that merit in the main examination was assessed uniformly, thereby invoking the right to open category consideration. For the State or recruiting bodies, the only sustainable defence post this judgment is to point to a clear statutory or rule-based prohibition; administrative instructions or circulars will not suffice. Additionally, this case equips advocates with a strong tool to distinguish Pradeep Kumar by showing that their client fulfilled essential eligibility and merely used a legally sanctioned relaxation. Overall, the judgment shifts litigation focus from abstract reservation principles to a rule-centric and stage-specific analysis, making recruitment rules the centerpiece of every argument.

Cases Cited

  • Govt. (NCT of Delhi) v. Pradeep Kumar (2019) 10 SCC 120 — Distinguished. Authority that failure of essential eligibility bars migration; not applicable where relaxation is in qualifying marks only.
  • Jitendra Kumar Singh v. State of U.P. (2010) 3 SCC 119 — Followed. Migration to open category allowed where reserved candidates secured higher marks in uniform merit examination.
  • Vikas Sankhala v. Vikas Kumar Agarwal (2017) 1 SCC 350 — Followed. Open category is a merit category, not a general category quota.
  • Saurav Yadav v. State of U.P. (2021) 4 SCC 542 — Cited. Reaffirms merit-based migration principle.
  • Indra Sawhney v. Union of India (1992) Supp (3) SCC 217 — Foundation case on reservation jurisprudence; open category is for all.
  • Tej Prakash Pathak v. Rajasthan High Court (2025) 2 SCC 1 — Recent precedent on recruitment rules and migration.
  • Anjuman Ishaat-e-Taleem Trust v. State of Maharashtra (2025 SCC OnLine SC 1912) — Cited for Maharashtra teacher recruitment framework.
  • Union of India v. Sajib Roy; Union of India v. G. Kiran — Distinguished. Facts not applicable to present matrix.

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