Recruitment eligibility cannot be relaxed after the cut-off date without fresh notice; higher qualifications are not automatic equivalents.

Recruitment eligibility conditions ordinarily must be met by the last date for applications, and any relaxation must be expressly reserved and publicly notified; a post-deadline relaxation without fresh publicity was invalid. The prescribed diploma qualification could not be expanded by a supposed ambiguity where the recruitment framework required recognition under the governing rules, and clarification could not substitute for a proper change in criteria. Higher or different qualifications could not be treated as equivalent absent an express rule or authorised determination. An employer was also not bound to fill every advertised vacancy, and recruitment under amended rules could proceed under the later regime. The ratio emphasises fairness and equality in public employment under Articles 14 and 16.

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Issues: (i) whether the essential eligibility conditions could be relaxed after the last date for receipt of applications and without fresh publicity; (ii) whether the qualification prescription in the 2014 Rules was ambiguous enough to justify clarification or relaxation on the question of recognised institutions and equivalent diplomas; (iii) whether candidates holding higher or different qualifications could be treated as eligible in the absence of any rule or advertisement to that effect; and (iv) whether the State could be compelled to fill all advertised vacancies under the old rules or prevent recruitment under the amended rules.

Issue (i): whether the essential eligibility conditions could be relaxed after the last date for receipt of applications and without fresh publicity

Analysis: Eligibility conditions in a recruitment advertisement ordinarily must be satisfied by the last date fixed for receipt of applications. Even where the governing rules permit relaxation, that power must be reserved in the advertisement and its exercise must be made known by adequate publicity so that all similarly situated candidates get an equal opportunity to compete. A mid-stream relaxation, after the cut-off date and without extending the last date or issuing a proper corrigendum, changes the rules of the game after the process has begun and offends the constitutional requirement of fairness and equality in public employment.

Conclusion: The post-deadline relaxation was not legally sustainable and was invalid for the advertised posts.

Issue (ii): whether the qualification prescription in the 2014 Rules was ambiguous enough to justify clarification or relaxation on the question of recognised institutions and equivalent diplomas

Analysis: The prescribed qualification required a one-year diploma in specified computer disciplines from a recognised university or institution. The record did not establish any genuine ambiguity warranting a blanket relaxation in favour of private or otherwise unverified institutions. Where a statutory framework exists for recognition and affiliation, an institution cannot be treated as recognised dehors that framework. The impugned clarification went beyond mere interpretation and effectively altered the eligibility standard by introducing courses and institutions not covered by the original prescription, without a properly publicised change in the recruitment criteria.

Conclusion: The supposed ambiguity did not justify the relaxation, and the clarification could not validate eligibility for institutions or diplomas outside the prescribed regime.

Issue (iii): whether candidates holding higher or different qualifications could be treated as eligible in the absence of any rule or advertisement to that effect

Analysis: The rules and the advertisement specifically prescribed the qualifications to be possessed. In the absence of an express provision, a higher or different qualification cannot be presumed to include, or substitute for, the stated qualification. Equivalence is a matter for the employer or the rule-making authority, not for judicial expansion of the recruitment criteria. The claim that higher qualifications necessarily met the prescribed standard was therefore untenable.

Conclusion: Candidates not satisfying the prescribed qualifications could not be treated as eligible merely because they claimed higher or different qualifications.

Issue (iv): whether the State could be compelled to fill all advertised vacancies under the old rules or prevent recruitment under the amended rules

Analysis: An employer is not bound to fill every advertised vacancy and may proceed under a fresh or amended recruitment regime. A candidate in a select list has no indefeasible right to appointment. Once the governing rules changed, the State was entitled to carry forward or re-advertise vacancies in accordance with the amended rules, and recruitment for the later advertisement had to be governed by the then-operative regime.

Conclusion: The State could not be compelled to fill all vacancies under the old rules, and recruitment under the amended rules could proceed in accordance with the later notifications.

Final Conclusion: The challenge to the post-deadline relaxation succeeded in substantial part, the directions to redraw the merit list and split the later recruitment were set aside, the later recruitment was left to proceed under the extant rules, and the appointments already made in the earlier recruitment were not disturbed.

Ratio Decidendi: A relaxation of recruitment qualifications after the prescribed cut-off date, without prior reservation in the advertisement and without fresh public notice to all prospective candidates, is inconsistent with Articles 14 and 16 of the Constitution of India; likewise, higher or different qualifications cannot be treated as equivalent in the absence of an express rule or authorised determination by the employer or rule-making authority.

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