Districtwise recruitment limits and false declarations can justify candidature rejection where notification conditions are breached.

A districtwise recruitment condition limiting candidates to one district was treated as valid because it served administrative feasibility, avoided duplicated testing and ranking, and did not, on the stated facts, create hostile discrimination under Articles 14 and 16. Rejection of candidature was also upheld where applicants applied in more than one district or made false declarations in the application form, since the notification and rules expressly made such conduct liable to summary rejection. The article further notes that reading down was unnecessary and equitable relief was unavailable because the candidates had breached the notified conditions, so no interference was called for.

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Issues: (i) whether a notification restricting a candidate to apply for only one district in districtwise recruitment violated Articles 14 and 16 of the Constitution of India; (ii) whether rejection of candidature for applying in more than one district or making a false declaration in the application form was lawful; (iii) whether the restriction could be read down or relief granted on equitable grounds.

Issue (i): Whether a notification restricting a candidate to apply for only one district in districtwise recruitment violated Articles 14 and 16 of the Constitution of India.

Analysis: The recruitment scheme permitted a candidate to choose any one district, but prohibited simultaneous applications to multiple districts in the same notification. The restriction was designed to prevent administrative complications in districtwise selection, avoid duplication of testing and ranking, and ensure workable recruitment. The cases relied upon concerning zonewise or unitwise admission and selection were distinguished, as those involved material discrimination or denial of equal chance among candidates. No factual foundation was laid to show that the impugned restriction caused hostile discrimination or deprived more meritorious candidates of employment while allowing inferior candidates to succeed.

Conclusion: The restriction was not unconstitutional and did not infringe Articles 14 and 16.

Issue (ii): Whether rejection of candidature for applying in more than one district or making a false declaration in the application form was lawful.

Analysis: The governing rules and notification expressly required the candidate to apply in only one district and treated applications to more than one district as liable to summary rejection. The application form also required a truthful answer on whether the candidate had applied in any other district. The short notification referred candidates to the detailed gazette notification, and the application form itself warned candidates to read the relevant gazette notification before filling it up. On the facts, some candidates falsely answered the relevant question and others applied in more than one district in direct breach of the notified conditions. The misconduct fell within the disqualifying provisions governing false statements and breach of selection conditions.

Conclusion: Rejection of candidature was valid and the candidates had no enforceable claim to selection.

Issue (iii): Whether the restriction could be read down or relief granted on equitable grounds.

Analysis: Reading down is not warranted where the provision is valid on its face and operates consistently with the recruitment scheme. The fact that the written test was held on the same day in all districts did not alter the legality of the restriction. Equitable relief was also unavailable because the appellants had acted in breach of the notification and had made false declarations. The Court declined to disturb the already selected candidates or to grant consideration merely because some appellants had crossed the upper age limit.

Conclusion: No reading down or equitable relief was called for.

Final Conclusion: The recruitment condition limiting a candidate to one district was upheld, the rejection of the appellants' candidature was sustained, and the appeals failed.

Ratio Decidendi: A districtwise recruitment restriction confining a candidate to one district is valid where it serves administrative feasibility and does not create unconstitutional discrimination, and candidature may be rejected for breach of the notified condition or for making a false declaration in the application form.

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