Legal Review and Analysis of Rajasthan High Court & Anr vs Rajat Yadav & Ors 2025 INSC 1503
Case Synopsis
Rajasthan High Court & Anr. vs Rajat Yadav & Ors. (2025 INSC 1503)
Reconciling Merit and Reservation in Recruitment Stages.
The Supreme Court held that the Open category in public employment is to be determined by pure merit from the initial shortlisting stage. A reserved category candidate who scores above the General category cut-off without any concession must be treated as an Open category candidate at that stage itself, and not confined to their reserved quota. This prevents the Open category from becoming an exclusive compartment and upholds the constitutional mandate of equality.
1. Heading of the Judgment
Case Name: Rajasthan High Court & Anr. vs Rajat Yadav & Ors.
Citation: 2025 INSC 1503, Civil Appeal No. 14112 of 2024
Court: Supreme Court of India
Bench: Justice Dipankar Datta and Justice Augustine George Masih
Date of Judgment: December 19, 2025
2. Related Laws and Constitutional Provisions
The judgment primarily interprets and applies the following constitutional and legal principles:
Articles 14 & 16 of the Constitution of India: Guaranteeing equality before law and equality of opportunity in matters of public employment.
Article 335 of the Constitution of India: Concerning the claims of Scheduled Castes and Scheduled Tribes to services and posts.
The Doctrine of Reservation & Migration: As elucidated in landmark precedents like Indra Sawhney v. Union of India and Saurav Yadav v. State of Uttar Pradesh.
Rajasthan High Court Staff Service Rules, 2002: The recruitment rules governing the selection process in question.
3. Basic Judgment Details
A. Facts of the Case
The Rajasthan High Court advertised posts for Junior Judicial Assistant/Clerk Grade-II. The selection was a two-stage process: a written test (300 marks) followed by a computer typewriting test (100 marks). The advertisement stipulated shortlisting candidates for the second stage at five times the category-wise vacancies. After the written test, the High Court prepared separate merit lists for each category (General, SC, ST, OBC-NCL, etc.). The cut-off marks for several reserved categories (like OBC-NCL, EWS) were set higher than the cut-off for the General category. Consequently, many reserved category candidates who scored more than the General category cut-off were excluded from the shortlist for the typewriting test because they could not meet the even higher cut-off of their own reserved category. These candidates filed writ petitions challenging this exclusion.
B. Issues Before the Supreme Court
Whether a reserved category candidate, who scores marks above the cut-off fixed for the General/Open category in a preliminary/written examination, is entitled to be shortlisted and considered under the Open category at that stage, or must they wait for "migration" only at the final selection stage?
Whether the principle of "estoppel" bars the candidates from challenging the selection process after having participated in it?
Whether allowing such inclusion amounts to granting a "double benefit" of reservation to the candidates?
C. Ratio Decidendi (Court's Reasoning)
The Supreme Court upheld the impugned judgment of the Rajasthan High Court. The core reasoning is as follows:
On Estoppel: The Court held that the plea of estoppel does not apply. Candidates cannot be estopped from challenging a process that suffers from a constitutional or legal infirmity which was not apparent at the time of participation. The illegality of excluding more meritorious reserved candidates from the Open category list was not foreseeable.
On Double Benefit: The Court rejected the argument of "double benefit." It clarified that when a reserved category candidate is placed in the Open category based purely on merit (without availing any relaxation/concession), they are not availing the benefit of reservation at all. Therefore, the question of a double benefit does not arise.
On Migration and Merit: This is the central and most significant part of the reasoning. The Court de-emphasized the term "migration" for this scenario. It held that the Open category is not a "quota" but is open to all on the basis of merit. If a reserved category candidate, without availing any special concession, outscores General category candidates in the written test, they must, from that very stage, be treated as an Open category candidate. There is no need for a separate "migration" at the final stage; their merit itself places them in the Open category pool. Confining them to their reserved category despite higher merit violates Articles 14 and 16.
Distinguishing Precedents: The Court distinguished its earlier judgment in Chattar Singh v. State of Rajasthan, noting that it applied to a preliminary exam where marks were not carried forward to the final merit list. In the present case, the written test carried 75% weightage and was a substantive part of the final selection, not a mere screening test.
Proper Procedure: The Court outlined the correct method: First, prepare a common merit list for the Open category based purely on marks, including all candidates (irrespective of category) who score above the Open category cut-off and have taken no concession. Shortlist from this pool. Only thereafter, prepare the reserved category lists from the remaining candidates.
4. Core Principle of the Judgment
Title: Primacy of Merit in the Open Category: A Necessary Check Against Compartmentalised Reservation
The Main Issue: The core issue addressed was the timing and philosophy of integrating meritorious reserved category candidates into the Open category stream. The appellants argued for a "compartmentalised" approach where category-wise lists are created at every stage, with migration occurring only at the final appointment stage. The respondents (candidates) argued for a "merit-first" approach where the Open category is truly open from the initial shortlisting stage itself.
What the Supreme Court Addressed: The Supreme Court firmly endorsed the "merit-first" approach. It addressed the misconception that the Open/General category is itself a reserved compartment for candidates not belonging to SC/ST/OBC. The Court held that such an interpretation is constitutionally impermissible as it transforms the Open category into a de facto "General caste" quota, negating merit.
Analysis: The judgment performs a deep analysis of the concept of "migration," ultimately finding it inapplicable at the initial shortlisting stage in the present context. The Court reasoned that "migration" implies a movement from a reserved slot to an open slot. However, if a candidate's merit is high enough to place them in the open slot from the outset—based on a common, category-neutral standard—they are not "migrating." They are rightfully occupying the open slot on merit. To hold otherwise would mean a candidate's social identity would override their demonstrated merit at the initial stage, which is anathema to the equality code. The Court affirmed that reservation is a tool for inclusion, not a tool to ghettoise meritorious candidates from backward classes within their reserved compartments when they are capable of competing on equal terms.
5. Final Outcome
The Supreme Court dismissed the appeals filed by the Rajasthan High Court administration. It upheld the directions of the Division Bench of the Rajasthan High Court, which required:
Re-working the selection lists by first preparing the Open category list on pure merit, including eligible reserved category candidates.
Then preparing the reserved category lists from the remaining candidates.
Giving a fresh opportunity to appear in the typewriting test to candidates who were wrongly excluded.
Making appointments based on the re-worked merit lists, possibly displacing less meritorious appointees if necessary, while cautioning the High Court to avoid dislodging existing employees as far as possible.
The time for compliance was extended by two months from the date of the Supreme Court's judgment.
6. MCQs Based on the Judgment
Q1. According to the Supreme Court in Rajasthan High Court vs. Rajat Yadav (2025 INSC 1503), under what condition must a reserved category candidate be placed in the Open category shortlist after a written examination?
a) Only if they have not availed any age relaxation.
b) Only at the final stage of preparing the merit list for appointment.
c) If they secure marks above the Open category cut-off without availing any concession/relaxation.
d) Only if the recruitment rules explicitly mention the process of migration.
Q2. The Supreme Court distinguished its earlier ruling in Chattar Singh v. State of Rajasthan primarily on which ground?
a) The nature of concessions availed by the candidates was different.
b) In Chattar Singh, the preliminary exam marks were not carried forward to the final merit list, unlike in the present case.
c) Chattar Singh dealt with horizontal reservation, while the present case dealt with vertical reservation.
d) The Court overruled the principle laid down in Chattar Singh.