Madras High Court· 09 September 2026

Must a candidate have studied in Tamil medium from elementary education till the prescribed qualification to claim the PSTM quota?

M.Premkumar v. THE TAMILNADU Public SERVICE COMMISSION

WP.1639/2022 · 2026:MHC:3732 · W.P.No.1639 of 2022
Coram: Justice C.Kumarappan

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Answer

A candidate must have studied in Tamil medium from elementary education till the prescribed qualification to claim the PSTM quota.

Yes. A candidate must have studied in Tamil medium from elementary education till the prescribed qualification to claim the PSTM quota. The phrase 'qualification prescribed' includes study from the stage of elementary education till the attainment of the required qualification prescribed for the post, so a Tamil medium certificate at degree level alone does not suffice. (¶12, 17)

Headnote

Tamil Nadu Act 40 of 2010 — s.2(d) — Tamil Nadu Act 35 of 2020 — Preferential appointment — Persons studied in Tamil Medium — Certificate verification — Tamil Nadu Act 40 of 2010 — s.2(d) — PSTM reservation — Tamil medium from elementary education — Held: To claim the preferential PSTM quota a candidate must have studied in Tamil medium from the stage of elementary education till and including the prescribed qualification. (¶12, 17) Tamil Nadu Act 35 of 2020 — Clarificatory and curative amendment — Retrospective operation — Held further: The amendment is clarificatory and curative, and governs recruitments notified before it, whichever notification is in question. (¶10, 11) Tamil Nadu Act 40 of 2010 — Fresh PSTM selection list — Supernumerary accommodation — Held further: Where selection proceeded on degree-level certificates alone, a fresh PSTM list must be prepared without disturbing appointments already made. Writ petition allowed with directions. (¶18, 21)

Headnote

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In the Court's own words

Paragraph 12Further, it is relevant to refer to the judgment of the Madurai Bench of this Court in A.Anbalagan’s case (cited supra), which reads as follows:- “12.Therefore, it is amply clear that the phrase ‘qualification prescribed’ would include study from the stage of elementary education till the attainment of the required qualification prescribed for the post. Accordingly, and to have the benefit of preferential PSTM quota, the law stands settled that the candidate should have studied in Tamil medium from the stage of elementary education till, and including, the prescribed degree.” In the above judgment, this Court has held that even in respect of any recruitment that had taken place prior to Act 35 of 2020, the same must also be considered in accordance with the amended provision, as the amendment is only curative and clarificatory in nature.

Paragraph 17In the case in hand, as per the Positional Note, except the petitioner, the other candidates PSTM certificates are only for their degree qualification. Whereas the petitioner possessed PSTM certificates covering his entire studies upto the qualified degree. Therefore, this Court is of the firm view that the petitioner squarely comes within the definition of a PSTM candidate as laid down in G.Sakthi Rao’s case (cited supra). However, on account of not securing marks over and above the other candidates, he was not considered.

Acts & Sections

s.2(d) Tamil Nadu Act 40 of 2010Tamil Nadu Act 35 of 2020

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Also decided in this judgment

Is Tamil Nadu Act 35 of 2020 clarificatory and applicable retrospectively from the date of the earlier Act 40 of 2010?Is the principle laid down on PSTM reservation applicable only to the notification impugned in that case?

Plain-language answer prepared by the LexStreak Editorial Desk — verify against the judgment. Source: Madras High Court. Corrections