Supreme Court Clarifies: Reserved Category Candidates Availing Relaxations Cannot Migrate to General Seats If Rules Forbid

On September 9, 2025, the Supreme Court of India delivered a significant judgment on the eligibility of reserved category candidates in government recruitment, particularly in cases where such candidates seek to be considered for unreserved (general) category seats.

This ruling has wide implications for recruitment processes under the Staff Selection Commission (SSC), Railway Protection Force (RPF), Central Industrial Security Force (CISF), and other public employment examinations.

The Case at a Glance

The ruling came in the matter of Union of India & Ors. v. Sachin Gupta & Ors. (Civil Appeal No. 6497 of 2025, decided on 09.09.2025).

The Core Issue

The question before the Court was:

👉 Can a reserved category candidate who has availed relaxations (such as in age, attempts, or qualifications) still be considered against general category vacancies, if they score higher than the last selected general candidate?

Supreme Court’s Key Findings

1. Migration Depends on Recruitment Rules

• The Court held that migration from reserved to general category is not automatic.

• If the recruitment notification, standing orders, or office memoranda impose a bar, then reserved category candidates availing relaxations cannot claim general seats.

2. When Migration is Allowed

• If the recruitment rules do not forbid migration, candidates from reserved categories can be adjusted in the general category merit list, provided their marks are higher than the cut-off for general candidates.

3. Precedent in Saurav Yadav v. State of UP (2020) 4 SCC 542

• The Court reaffirmed its earlier position that migration is possible only if no bar exists in the recruitment framework.

• In the present case, since an Office Memorandum dated July 1, 1998 expressly barred migration for those who availed relaxations, the Court overturned the High Court’s order that had allowed such migration.

Application to Specific Cases

SSC Constable (GD) Recruitment

• The Office Memorandum (1998) categorically stated that SC/ST/OBC candidates who availed relaxations in age, qualification, experience, or attempts shall not be eligible for unreserved vacancies.

• Hence, migration was barred.

RPF Recruitment (Railway Protection Force)

• Standing Order No. 85 (2009) and Revised Directive No. 29 (2013) barred candidates who availed relaxations in age or physical criteria from being considered under general vacancies.

• The Supreme Court upheld this bar.

CISF Recruitment (Central Industrial Security Force)

• The Court made an important distinction:

  • Physical standard relaxations (like height or chest measurement) do not fall within the “relaxations” covered by the Office Memorandum.

  • Therefore, candidates availing such relaxations can still migrate to the general list if their marks are higher.

Why This Matters

This judgment provides clarity for millions of candidates preparing for competitive exams. It strikes a balance between merit-based migration and rule-based restrictions, ensuring that the recruitment process remains consistent with notified rules.

In essence:

• No prohibition = migration allowed (if marks are higher).

• Explicit prohibition = migration barred (even with higher marks).

• Physical relaxations stand on a different footing and do not automatically bar migration.

Conclusion

The Supreme Court’s ruling in Union of India & Ors. v. Sachin Gupta & Ors. reinforces a simple but powerful principle: the recruitment rules are the ultimate authority. Reserved category candidates cannot claim general seats by default; their eligibility depends entirely on whether the recruitment framework permits migration after availing relaxations.

This judgment not only settles ambiguity in ongoing SSC, RPF, and CISF recruitments but also sets a clear precedent for future public employment processes.