1986 (8) TMI 443 - SC - Indian Laws

Supreme Court Upholds Age Limit Disqualification for Recruitment

Prabhu Dayal Sesma Versus State Of Rajasthan

The Supreme Court affirmed the Division Bench's decision that the appellant had exceeded the age limit by one day and was disqualified for direct ... - Issues:Age determination for eligibility in direct recruitment to Rajasthan Administrative Service under the Rules.Analysis:The case involved the determination of age for eligibility in direct recruitment to the Rajasthan Administrative Service. The appellant's date of birth was January 2, 1956, and the question was whether he had attained the age of 28 years on January 1, 1984, making him ineligible for consideration under the Rules. The Rajasthan Public Service Commission had prescribed a minimum age of 21 years and a maximum of 28 years for candidates applying for the service. The appellant's candidature was rejected on the grounds of exceeding the age limit, leading to a legal challenge. The High Court initially ruled in favor of the appellant, stating that he had not attained the age of 28 years on January 1, 1984, as claimed by the Commission.However, on appeal, a Division Bench disagreed with the Single Judge's interpretation. They emphasized the specific language of the Rules, which stated that a candidate 'must not have attained the age of 28 years on the first day of January next following the last date fixed for receipt of application.' The Bench concluded that the appellant, born on January 2, 1956, had indeed attained the age of 28 years on January 1, 1984, making him ineligible for the examination under the Rules. They referred to legal principles regarding age determination and previous court decisions to support their interpretation.The appellant argued that the Union Public Service Commission interpreted similar age requirements differently, but the Supreme Court held that the interpretation of the Rules could not be based on the Commission's practices. The Court analyzed the language of Rule 11-B, emphasizing that a person attains a specified age on the day preceding the anniversary of their birth day. They cited legal principles and English court decisions to support this interpretation. The Court also highlighted the Indian Majority Act, 1875, which provides guidelines for computing a person's age.Ultimately, the Supreme Court affirmed the Division Bench's decision, ruling that the appellant had exceeded the age limit by one day and was disqualified for direct recruitment to the Rajasthan Administrative Service. The Court acknowledged the potential hardship faced by the appellant due to this strict interpretation of age limits and suggested the need for provisions allowing for age limit relaxations in deserving cases. The appeal was dismissed, and no costs were awarded.