Union of India v. G. Kiran 2026 INSC 15. Reservation - UPSC Rules
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Reservation- Rules for a competitive examination to be held by the Union Public Service Commission in 2013 - Once relaxation has been taken by a reserved category candidate, they cannot be considered for unreserved vacancies.If a reserved category candidate takes benefit of relaxation though at initial stage, it will effectively amount to taking relaxation even at the final stage of the selection process because without giving relaxation to him, he was not in a position to participate in the Main examination and to set forth his claim of cadre allocation. (Para 32) A reserved category candidate selected applying ‘General Standard’ has eligibility for allocation on unreserved vacancy as per his merit and preference if he is not lower in rank from other General category candidates, otherwise he shall be considered for allocation as per his merit and preference against the available vacancy of his category. In the said context, it is clear that for allocation of unreserved vacancy to a candidate of reserved category, the selection must be on ‘General Standard’ without availing any ‘Relaxed Standard’ in either eligibility or selection criteria. In case any ‘Relaxed Standard’ has been availed by him, his allocation of cadre would be as per his merit and preference against vacancy of his category. (Para 24)
Case Info
Case:
Key Details
- Coram: J.K. Maheshwari, J.; Vijay Bishnoi, J.
- Judgment date: January 6, 2026.
Connected Appeals and Case Title
- Civil Appeal arising out of SLP (C) No. 4743 of 2020: Union of India … Appellant versus G. Kiran & Ors. … Respondents.
- Civil Appeal arising out of SLP (C) No. 4067 of 2022: Antony S. Mariyappa … Appellant versus G. Kiran & Ors. … Respondents.
Caselaws and Citations
- Deepa E.V. v. Union of India & Ors., (2017) 12 SCC 680.
- Gaurav Pradhan v. State of Rajasthan, (2018) 11 SCC 352.
- Niravkumar Dilipbhai Makwana v. Gujarat Public Service Commission, (2019) 7 SCC 383.
- Union of India v. Sajib Roy, (2025) SCC OnLine SC 1943.
- Jitendra Kumar Singh v. State of U.P., (2010) 3 SCC 119.
- Ajithkumar P. v. Remin K. R., (2015) 16 SCC 778.
- Vikas Sankhala v. Vikas Kumar Agarwal, (2017) 1 SCC 350.
Statutes/Rules/Policies Referred
- Constitution of India: Articles 14 and 16 (including Article 16(4) as enabling provision).
- Exam Rules, 2013 (Indian Forest Service Examination Rules):
- Rule 1 (two-tier examination structure).
- Rule 13 and its proviso (minimum qualifying marks; relaxed standards for SC/ST/OBC).
- Rule 14(i)-(ii) and proviso (general qualifying standard; relaxed standard; embargo on adjustment to UR if relaxation availed at any stage).
- Rule 17 (cadre preference and allotment governed by policy in force).
- Cadre Allocation Policy for All India Services:
- Policy dated 10 April 2008, as amended on 21 April 2011, Paragraph 9 (allocation of reserved candidates selected on general standards to unreserved vacancies).
- Office Memorandum (DoPT) dated 01.07.1998 (relaxed standard candidates counted against reserved vacancies).
- State circulars discussed in precedents (e.g., Rajasthan circulars dated 24.06.2008 and 11.05.2011; Gujarat circulars dated 21.01.2000 and 23.07.2004) as context in cited cases.
