Supreme Court Holds Reserved Category Candidate Availing Relaxation at Preliminary Stage Cannot Claim General Insider Cadre; Sets Aside Tribunal and High Court Orders

Case Name: Union of India v. G. Kiran & Others (with connected appeal Antony S. Mariyappa v. G. Kiran & Others)
Citation: 2026 INSC 15
Date of Judgment/Order: 06 January 2026
Bench: J.K. Maheshwari, J.; Vijay Bishnoi, J.

Held: The Supreme Court held that a Scheduled Caste candidate who qualified the Indian Forest Service Preliminary Examination by availing relaxed cut-off marks cannot be regarded as a candidate selected on “general standards” for the purpose of allocation against an unreserved General Insider vacancy, even if he subsequently secured higher marks than a general category candidate in the Main Examination and Interview, as relaxation at any stage of the examination disentitles migration to unreserved vacancies under the IFS Examination Rules, 2013 read with the Cadre Allocation Policy.

Summary: The dispute arose from the 2013 Indian Forest Service examination, where Respondent No.1, a Scheduled Caste candidate, qualified the Preliminary Examination by availing the relaxed SC cut-off, while Respondent No.3, a general category candidate, qualified on general cut-off marks. Although Respondent No.1 secured a higher rank than Respondent No.3 in the final merit list based on the Main Examination and Interview, the Ministry allocated the General Insider vacancy of Karnataka to Respondent No.3 and allotted Respondent No.1 to the Tamil Nadu cadre. The Central Administrative Tribunal and the Karnataka High Court held that since the Preliminary Examination was only a screening test and final merit was based on the Main Examination, Respondent No.1 should be treated as a general merit candidate. The Supreme Court examined Rules 1, 13, 14, and 17 of the IFS Examination Rules, 2013 along with Paragraph 9 of the Cadre Allocation Policy, and held that the Preliminary Examination is an integral stage of the examination process, and any relaxation availed at that stage constitutes relaxation “at any stage of the examination.” Relying on precedents including Deepa E.V., Gaurav Pradhan, Niravkumar Dilipbhai Makwana, and Sajib Roy, the Court rejected the High Court’s interpretation and reaffirmed that reserved category candidates who avail relaxation cannot migrate to unreserved vacancies.

Decision: The Supreme Court allowed the appeals, set aside the judgments of the Karnataka High Court dated 06 August 2019 and the Central Administrative Tribunal dated 15 March 2016, and upheld the notification dated 13 March 2015 allocating the General Insider vacancy of Karnataka to the general category candidate and the Tamil Nadu cadre to the Scheduled Caste candidate, holding the cadre allocation to be legally valid, with no order as to costs and all pending applications disposed of.