‘No sympathetic exceptions’: Madhya Pradesh High Court dismisses aspirant’s plea over late document submission

“Granting individual relaxation on equitable or sympathetic considerations would not only violate the settled principles of service jurisprudence but would also set an unhealthy precedent, eroding the sanctity of the recruitment process,” the court said, rejecting her plea.

Background

• The petitioner, who has qualified the State Eligibility Test (SET-2022), submitted her online application for the post of Assistant Professor in April 2024, and later appeared in the written examination conducted in June 2024.
• The result was declared in October 2024, wherein the petitioner was placed in the provisional merit list.
• The result also included instructions for submission of the required documents within a prescribed time limit, which were later extended twice with late fees.

• However, the petitioner failed to submit the documents within the original period or within the extended periods.
• Subsequently, she submitted a representation in November 2024, citing her ill health as the reason for the non-submission of documents, which was rejected.
• Aggrieved by this decision, she filed the present writ petition and was permitted to participate in the interview, subject to the outcome of the petition, by an interim order of December 2024.

Findings

• The responsibility to regularly monitor the commission’s website for all information relating to the advertisement, amendments, results and further instructions is solely upon the candidate.
• The cut-off date is not flexible, discretionary or subject to individual hardship.
• The petitioner admittedly failed to submit her documents within the prescribed time period, even after extensions were granted with late fees.
• The plea of medical incapacity, in the absence of any enabling provision for relaxation under the advertisement or recruitment rules, cannot be accepted as a legally sustainable ground to override mandatory conditions governing public recruitment.

• Recruitment to public posts is governed by the principles of certainty, transparency and equal opportunity.
• Public employment must be regulated by certainty, uniformity and adherence to prescribed timelines so as to ensure equal opportunity to all eligible candidates.
• The selection process for the post in question had already been duly concluded and the result finalised in July, 2025.
• Once a selection process has attained finality, the same should not be unsettled at a belated stage.
• No illegality, arbitrariness or violation of statutory provisions has been demonstrated, requiring interference with the concluded selection.
• Any direction to reopen or disturb the finalised process would not only be contrary to settled principles of law but would also adversely affect the rights of candidates duly selected as per the law.

Arguments

• Appearing for the petitioner, advocate Prasanna R Bhatnagar argued that his client is fully qualified and has successfully cleared the written examination, and therefore deserves consideration for appointment.
• Bhatnagar further argued that the delay was neither deliberate nor intentional, as his client was suffering from Mixed Connective Tissue Disease (MCTD), which prevented her from checking the result and submitting documents within time.
• He also emphasised that the commission concerned itself extended the last date multiple times on payment of late fees and therefore, the cut-off date cannot be treated as rigid or mandatory.
• Advocate Vindhyavashini Prasad Khare, representing the commission, argued that they are merely a recruiting agency and that the entire selection process is governed strictly by the terms and conditions of the advertisement and the instructions issued thereunder.
• Khare further pointed out that the October 4, 2024, result clearly stipulated that all requisite documents were to be submitted on or before October 25, 2024, failing which the candidature of the concerned candidate was liable to be cancelled.
• He highlighted that despite two extensions being granted on payment of substantial late fees for submission of the documents, the petitioner failed to submit the same.