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Supreme Court of India· 23 March 2026

Is a reserved category candidate who does not fulfil the essential eligibility criteria prescribed for a selection entitled to migrate to the open category?

Chaya & Ors. Etc. v. The State of Maharashtra & Anr. Etc.
2026 INSC 277
Coram: Pamidighantam Sri Narasimha; Alok Aradhe
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Answer

No. If a candidate belonging to a reserved category does not fulfil the essential eligibility criteria prescribed for a selection, he or she cannot be permitted to migrate to an open category. That was the position in Pradeep Kumar, where the respondents neither had the OBC certificates issued by NCT of Delhi nor had passed the CTET with 60% marks.

Headnote

Right of Children to Free and Compulsory Education Act, 2009 — s.23 — NCTE Guidelines dated 11.02.2011 — Clause 9 — Teacher Eligibility Test — Relaxation in qualifying marks — Migration to open category — Reservation — NCTE Guidelines dated 11.02.2011 — Clause 9 — Relaxation in qualifying examination — level playing field, merit unaffected — Held: A relaxation in the qualifying examination merely enables entry into the zone of consideration and creates a level playing field. It is not a relaxation in the standard where inter se merit is determined solely on performance in the main examination. (¶19, 28) Recruitment Rules — Employment notification — Migration of reserved category candidate to open category — Held further: Migration of a reserved category candidate who availed a concession in the qualifying examination depends on the Recruitment Rules or employment notification. It is permissible where these permit it, or are silent and do not expressly prohibit it. (¶19) Right of Children to Free and Compulsory Education Act, 2009 — s.23 — Essential eligibility criteria — non-fulfilment bars migration — Held further: A reserved category candidate who does not fulfil the essential eligibility criteria prescribed for a selection cannot migrate to an open category. Where the NCTE guidelines themselves permit relaxation, 60% marks in TET is not an essential eligibility condition. (¶19, 31) Teachers Aptitude and Intelligence Test, 2022 — Merit list — exclusion of more meritorious reserved candidate impermissible — Held further: Appellants more meritorious than the last selected candidate under the general category cannot be excluded from consideration under that category in the absence of any express prohibition in the Recruitment Rules or notification. Impugned judgment quashed and set aside; appeals allowed. (¶32, 33)

In the Court's own words
Paragraph 15In Pradeep Kumar (supra), a three-Judge Bench considered whether candidates qualifying CTET with relaxed marks from the States other than Delhi could compete for unreserved vacancies for recruitment of Special Education Teachers in NCT of Delhi. The essential qualifications prescribed for passing the CTET Test was to secure a minimum of 60% marks in CTET. The respondents who were the candidates belonging to OBC category and were from outside Delhi and neither had OBC certificates issued by NCT of Delhi nor fulfilled the essential eligibility criteria for passing the CTET with 60% marks, were seeking consideration under the open category. A three-Judge Bench of this Court, inter alia held that the respondents did not fulfil the essential eligibility criteria in as much as they neither had the OBC certificates issued by NCT of Delhi nor had passed the CTET with 60% marks. Therefore, they could not be considered against the vacancies of Special Education Teachers of open category. This Court distinguished the decision in Vikas Sankhala (supra) and held that migration of such candidates to open category is impermissible.
Paragraph 19From the aforesaid decisions, the following legal principles can be culled out: -
Acts & Sections
s.23 Right of Children to Free and Compulsory Education Act, 2009s.23(1) Right of Children to Free and Compulsory Education Act, 2009s.2(n) Right of Children to Free and Compulsory Education Act, 2009Art. 16(1) Constitution of IndiaArt. 14 Constitution of Indias.8(1) U.P. Public Services (Reservation for SC, ST and OBC) Act, 1994

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Also decided in this judgment
Under the NCTE Guidelines for the Teacher Eligibility Test, can a reserved category candidate who availed relaxation in the qualifying marks in TET migrate to the open category on the strength of higher merit in the main selection examination?Under the Recruitment Rules or employment notification governing a selection, when does migration of a reserved category candidate who has availed a concession in the qualifying examination to the open category become permissible?Under the Right of Children to Free and Compulsory Education Act, 2009 and the NCTE guidelines dated 11.02.2011, is securing 60% marks in the Teacher Eligibility Test an essential eligibility condition where the guidelines themselves permit concessions to reserved categories?Where a qualifying test carries only a limited weightage in the final merit list, does a lower score obtained under relaxed qualifying marks give a reserved category candidate any advantage in the ultimate selection?Do concessions in fee and age granted to reserved category candidates amount to a relaxation in the standard prescribed for qualifying the written examination?
Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Supreme Court of India. Corrections