Yogendra Singh Gurjar vs Airport Authority Of India And Others

Jai Kumar Pillai, J

The present writ petition under Article 226 of the Constitution of India has been preferred by the petitioner invoking a Writ of Certiorari to quash the decision of the verification committee dated 31.01.2026, whereby the petitioner’s candidature for the post of Junior Assistant (Fire Services) under the Airports Authority of India (Western Region) was rejected. The petitioner further seeks a Writ of Mandamus directing the respondents to consider his candidature, accept his domicile certificates, and permit him to participate in the remaining stages of the selection process.

The facts of the case are that the respondent No.2 issued Advertisement No.DR-01022025WR dated 11.02.2025 for the direct recruitment of Non-Executives, including the post of Junior Assistant (Fire Services). The advertisement mandated that candidates must be domiciles of Maharashtra, Gujarat, Madhya Pradesh, or Goa.

The petitioner, born on 04.10.2000 and claiming to be a permanent resident of Madhya Pradesh since birth, applied online for the said post prior to the last date of submission. During the online application process, the Petitioner uploaded the domicile certificate of his father, Shri Laxman Singh Gurjar, dated 14.06.2016, instead of his own within the last date i.e. 24.03.2025.

The petitioner was issued an E-Admit Card and successfully cleared the Computer Based Test (CBT) held on 06.06.2025. Consequently, he was issued a Call Letter dated 24.12.2025 directing him to appear for document verification on 31.01.2026 at Vadodara Airport.

During the document verification, the petitioner produced his educational certificates, a Light Motor Vehicle Driving Licence, his father’s domicile certificate dated 14.06.2016, and his own domicile certificate dated 05.01.2026. The verification committee orally rejected the Petitioner’s candidature on the ground that he failed to produce his own domicile certificate issued prior to the cut-off date for filing the application form i.e. 24.03.2025.

Learned counsel for the petitioner submitted that the rejection of the Petitioner’s candidature is arbitrary, illegal, and violative of Articles 14, 16, and 21 of the Constitution. It was contended that the advertisement only required a domicile certificate in the prescribed format and did not stipulate any cut-off date for its issuance.

It was further argued that a domicile certificate merely evidences a pre-existing fact of permanent residence and does not create the status. The petitioner’s continuous residence in Madhya

Pradesh is conclusively established by his educational records, Samagra ID, and his father’s 2016 domicile certificate. The Petitioner’s own certificate dated 05.01.2026 validates this continuous status.

Lastly, the petitioner contended that the oral rejection without providing a prior show-cause notice, an opportunity to be heard, or a reasoned written order amounts to a gross violation of the principles of natural justice and defeats his legitimate expectation of fair treatment after successfully clearing the CBT.

Per contra, learned counsel for the respondents raised a preliminary objection regarding the maintainability of the petition on the ground of territorial jurisdiction, submitting that the advertisement explicitly stipulated Mumbai as the forum for dispute resolution.

On merits, it was submitted that Clauses 6(i), 6(ii), 6(x), 8(e) (iii), and 8 (f) of the Advertisement mandatorily required the uploading of the candidate's scanned domicile certificate prior to the cut-off date of 24.03.2025. The petitioner failed to upload his own valid domicile certificate during the application stage, instead uploading his father's certificate, which constitutes incorrect information.

It was further contended that strict adherence to the eligibility conditions is mandatory in competitive recruitment. The petitioner produced his own domicile certificate dated 05.01.2026, well after the cut-off date. Providing relaxation to the Petitioner would amount to discrimination against other candidates who strictly adhered to the rules, including approximately 15 candidates who were similarly rejected for lacking valid domicile certificates on the cut-off date.

The respondents also submitted that the entire selection process including driving and physical endurance tests has already been concluded, and directing a re-conduct of the process for a single candidate would be administratively impracticable

This Court has carefully considered the rival submissions advanced by the learned counsel for the parties and perused the pleadings and materials available on record.

Before adverting to the merits of the petitioner's entitlement, the question of territorial jurisdiction is to be dealt with at the very first stage. This Court has examined the language spelled out with respect to territorial jurisdiction, and upon close scrutiny, it transpires that the language employed in this respect does not confine the territorial jurisdiction to the courts in Mumbai alone. Thus, in the absence of the parties' intention to confine the jurisdiction solely to the courts at Mumbai, this court would certainly have jurisdiction to dwell upon the issue in dispute.

This well-settled principle of law is squarely covered by the decision of the Hon'ble Supreme Court in the landmark case of A.B.C. Laminart (P) Ltd. v. A.P. Agencies, (1989) 2 SCC 163 : 1989 SCC OnLine SC 122, wherein at page 175, paragraph 21, the Apex Court held as under:-

“21. From the foregoing decisions it can be reasonably deduced that where such an ouster clause occurs, it is pertinent to see whether there is ouster of jurisdiction of other courts. When the clause is clear, unambiguous and specific accepted notions of contract would bind the parties and unless the absence of ad idem can be shown, the other courts should avoid exercising jurisdiction. As regards construction of the ouster clause when words like “alone”, “only”, “exclusive” and the like have been used there may be no difficulty. Even without such words in appropriate cases the maxim “expressio unius est exclusio alterius” — expression of one is the exclusion of another — may be applied. What is an appropriate case shall depend on the facts of the case. In such a case mention of one thing may imply exclusion of another. When certain jurisdiction is specified in a contract an intention to exclude all others from its operation may in such cases be inferred. It has therefore to be properly construed.”

The next pivotal question that falls for consideration is whether the candidature of the petitioner can be accepted on the strength of a domicile certificate issued in the name of his father, or a domicile certificate obtained by the Petitioner in his own name after the prescribed cut-off date mentioned in the advertisement.

It is an undisputed fact that the petitioner had applied for recruitment to the post of Junior Assistant (Fire Services) and was declared successful in the Computer Based Test. It is equally undisputed that the Advertisement No.DR-01022025WR specifically restricted the eligibility to candidates who are domiciles of Maharashtra, Gujarat, Madhya Pradesh, and Goa.

A bare perusal of the Advertisement reveals that the rules of the recruitment were clear, mandatory, and binding. Clause 6(ii) unequivocally stipulated that "age, educational qualification, experience and all other eligibility criteria shall be reckoned as on 24.03.2025 (cut-off date)." Furthermore, Clause 8(e)(iii) read with Clause 8(f) of the Advertisement mandatorily required the candidates to upload a scanned, self-attested copy of the "Domicile Certificate in the prescribed format of concerned state" at the time of submitting the online application.

Thus, it is clear that for claiming eligibility as a domicile of Madhya Pradesh, it was mandatory for the candidate to possess and upload a valid domicile certificate issued prior to the cut-off date of 24.03.2025. Undisputedly, the Petitioner did not upload his own domicile certificate during the online application process. Instead, he uploaded the domicile certificate of his father, Shri Laxman Singh Gurjar, which was issued on 14.06.2016.

As per the pleadings and the documents supplied, the Petitioner was born on 04.10.2000. Therefore, on the date of the issuance of his father's domicile certificate in 2016, the petitioner was a minor (approximately 16 years of age). However, by the cut-off date of 24.03.2025 stipulated in the Advertisement, the Petitioner was approximately 24 years of age, having long attained majority.

Following the established principles regarding domicile certification, once a person attains majority, he is required to obtain a domicile certificate in his own name. A domicile certificate issued in favor of a father during the candidate's minority cannot perpetually serve as the adult candidate's independent proof of domicile, especially when competing for public employment where strict adherence to documentary requirements is mandated. Therefore, the father's certificate dated 14.06.2016 cannot be treated as the valid domicile certificate of the Petitioner for the purpose of this recruitment.

The petitioner subsequently produced a domicile certificate issued in his own name on 05.01.2026. However, this certificate was obtained well after the cut-off date of 24.03.2025. While the petitioner contends that a domicile certificate merely evidences a pre-existing fact of permanent residence, this Court finds force in the respondents' submission that participation in a recruitment process requires strict compliance with essential eligibility conditions. The requirement was not merely to be a domicile, but to possess and upload the valid proof of such status prior to the cut-off date.

This Court also finds merit in the submission of the respondents that Clause 8.1 of the Advertisement categorically provided that any wrong information or incorrect document uploaded by a candidate may lead to rejection at any stage. By uploading his father's certificate instead of his own, the Petitioner failed to meet the mandatory application requirements. Furthermore, as submitted by the respondents, uniformity was maintained in the selection process, and approximately 15 other candidates who did not possess valid domicile certificates on the cut-off date were similarly rejected. Granting indulgence to the Petitioner would amount to an arbitrary relaxation of mandatory conditions and would result in reverse discrimination against those candidates who strictly adhered to the rules or were similarly rejected.

In absence of any power vested in the respondents under the Advertisement to relax the condition of producing a valid, cut-off-domicile certificate, it cannot be said that the respondents committed any mistake or illegality in rejecting the candidature of the Petitioner. The selection process is a highly competitive exercise, and as pleaded by the respondents, the entire process including physical and driving tests has already been concluded. The Courts must be slow in interfering with the process of recruitment where rejection flows automatically from the non-compliance of mandatory conditions by the candidate himself.

For the reasons stated hereinabove, this Court is of the considered opinion that the impugned action of rejecting the petitioner's candidature does not suffer from any manifest arbitrariness, unreasonableness, or violation of Articles 14, 16, or 21 of the Constitution of India.

Accordingly, this petition sans merit and is hereby dismissed.

Consequently, the interim order granted earlier stands vacated and all pending applications, if any, stand disposed of accordingly.