Court Affirms State Policy Authority, Denies Mandamus for Age Relaxation to EWS Candidates
In a significant ruling, the Madhya Pradesh High Court, Jabalpur Bench, dismissed an appeal challenging the non-grant of age relaxation to Economically Weaker Section (EWS) candidates in the recruitment process for the post of Assistant District Public Prosecution Officer (ADPO). The Division Bench, comprising Justices Pranay Verma and Jai Kumar Pillai, upheld the decision of the Single Bench, emphasizing that age relaxation is a matter governed by specific statutory rules framed by the State Government and falls within the domain of State policy.
The case, Suryakant Tiwari v. State of Madhya Pradesh, centered around the appellant's contention that excluding EWS candidates from age relaxation was arbitrary and discriminatory, violating Articles 14 and 16 of the Constitution. The appellant, a practicing advocate, argued that the absence of age relaxation negated the reservation benefits provided under Articles 15(6) and 16(6), rendering the constitutional provisions ineffective and merely symbolic.
The court, however, found that enabling constitutional provisions do not automatically vest an absolute right to claim age relaxation without a statutory framework. It reiterated that the principles governing reservations and concessions fall under the purview of the State's rule-making authority and policy decisions.
Furthermore, the court noted that administrative delay in the recruitment process could not be grounds for granting concessions not provided under statutory rules. The judgment emphasized that judicial intervention in policy matters is limited to instances where decisions are manifestly arbitrary or unconstitutional.
The court's decision reaffirms the distinct roles of the State and Central Governments in determining reserved categories and the associated relaxations and concessions. It highlighted that lists maintained by the State and Central Governments for reserved categories are separate, and a community included in one list cannot claim benefits under the other.
This ruling underscores the judiciary's deference to the executive's policy decisions in matters of reservations and relaxations, provided they are within the constitutional framework and not arbitrary.
Bottom line:-
Age relaxation for EWS candidates cannot be claimed as a matter of right unless specifically provided under statutory rules framed by the State Government. Courts cannot interfere in policy decisions unless they are manifestly arbitrary or unconstitutional.
Statutory provision(s): Articles 14, 15(6), 16(6), 226, 342A, 366(26C) of the Constitution of India
