Supreme Court holds essential qualification on application date is mandatory when rules do not allow final-year or later qualification.

Case Name: Rajasthan Public Service Commission v. Lavanshu Sankhla & Ors. with connected matters

Citation: 2026 INSC 444

Date of Judgment/Order: 4 May 2026

Bench: Justice Vikram Nath and Justice Sandeep Mehta

Held: The Supreme Court held that where the recruitment rules and advertisement require a candidate to “possess” the essential educational qualification, and no rule permits final-year candidates or later acquisition of qualification, eligibility must be determined with reference to the date of submission of the application. The Court held that candidates who had not acquired the law degree on the application date could not be treated as eligible merely because they obtained the qualification before the preliminary examination or before interview. The Court further held that what cannot be done directly cannot be permitted indirectly; once the earlier proviso allowing final-year candidates had been deleted from the Rajasthan Prosecution Subordinate Service Rules, 1978, such relaxation could not be reintroduced by interpretation.

Summary: The Rajasthan Public Service Commission issued an advertisement dated 7 March 2024 for 181 posts of Assistant Prosecution Officer requiring a Degree in Law or integrated law course as the essential qualification. The private respondents applied even though they had not acquired their law degree on the date of application and were still awaiting final-year completion. They later obtained the degree on 22 August 2024, before the preliminary examination scheduled for 19 January 2025. RPSC issued press notes clarifying that only candidates possessing the educational qualification by the last date of application would be eligible, since the governing 1978 Rules did not permit final-year candidates to participate. The Rajasthan High Court allowed the candidates to appear, reasoning that the advertisement could be interpreted to permit qualification up to the date of examination or interview. The Supreme Court reversed this view, holding that the deleted proviso to Rule 12 earlier permitting final-year candidates showed clear legislative intent that such candidates were no longer eligible unless they already possessed the qualification on the relevant application date.

Decision: The Supreme Court allowed the appeals filed by the Rajasthan Public Service Commission and set aside the common judgment dated 12 August 2025 passed by the Division Bench of the Rajasthan High Court in D.B. Special Appeal Writ No. 169 of 2025 and connected matters. The Court held that the press note dated 29 November 2024 was consistent with the Rajasthan Prosecution Subordinate Service Rules, 1978 and the advertisement dated 7 March 2024, and merely clarified that eligibility must be determined on the application date. All pending applications were disposed of.