West Bengal State Electricity Transmission Co. Ltd. v. Dipendu Biswas 2026 INSC 330 - Reservation - Open Category - Horizontal Reservation PwD

Reservation - Any post falling under the Unreserved or Open category does not pertain to any particular social category; it provides an open field or pool meant for the world at large, in the sense that it is open to all candidates, irrespective of whether one belongs to any social or special category or not. A post earmarked for special (horizontal) reservation under the Unreserved category will be open to every candidate possessing the attribute or character of the special (horizontal) reservation. (Para 27-28) [Context: The Supreme Court held that a horizontally reserved post for UR (PWD‑Low Vision) in the unreserved/open category can be filled by any more meritorious PWD‑LV candidate from a reserved social category (such as OBC‑A), so long as no relaxation in essential eligibility for the unreserved post is taken. It ruled that the Calcutta High Court’s Division Bench erred in reading the recruitment note (“in case of non‑availability of qualified UR (PWD‑LV) candidate…”) as barring such migration and treating “unreserved” as if it were its own communal category, contrary to established principles in Indra Sawhney and Saurav Yadav that unreserved posts are open to all and must be filled strictly by merit. ]