The Joint Admission Committee-2026 vs Vidya Sankar & Ors.

Anil K. Narendran, J.

These writ appeals filed by the Joint Admission Committee, Indian Institute of Science Education and Research, Berhampur, Odisha, arise out of the common judgment dated 13.08.2026 of a learned Single Judge of this Court in W.P.(C)Nos.26238 of 2026 and 27028 of 2026. W.A.No.1701 of 2026 arises out of the judgment in W.P.(C)No.26238 of 2026 and W.A.No.1702 of 2026 arises out of the judgment in W.P.(C)No.27028 of 2026.

W.A.No.1701 of 2026:- The 1^st respondent in this writ appeal, who applied for the IISER Aptitude Test (IAT) - 2026, in furtherance of Ext.P1 information brochure published by the Joint Admission Committee – 2026, the appellant herein, for admission to 5-year BS-MS (Dual Degree), 4-year BS and B.Tech Degree Programs - 2026 in Indian Institute of Science Education and Research (IISER) established by the Government of India at Berhampur, Bhopal, Kolkata, Mohali, Pune, Thiruvananthapuram and Tirupati, filed W.P.(C)No.26238 of 2026, invoking the extraordinary jurisdiction of this Court under Article 226 of the Constitution of India, aggrieved by the non-consideration of Ext.P2 non-creamy layer certificate dated 09.02.2026, which was uploaded along with her application for getting admission to 5-year BS-MS (Dual Degree) Program - 2026, on the ground that the said certificate uploaded by her was not issued in the financial year 2026-27. In the writ petition, the petitioner sought for a writ of certiorari to quash Ext.P9 e-mail communication dated 29.07.2026 issued by the 3^rd respondent (appellant herein), whereby the petitioner was informed that her candidature for selection under OBC-NCL category has been rejected, since she failed to submit a valid category certificate as per Ext.P1 information brochure, before the last date of 21.06.2026 specified therein, which was issued in March, 2026. The reliefs sought for in W.P.(C)No.26238 of 2026 read thus;

In W.P.(C)No.26238 of 2026, the information brochure for IISER Aptitude Test - 2026 is marked as Ext.P1. The document marked as Ext.P2 is a copy of the non-creamy layer certificate dated 09.02.2026 issued by the Tahsildar, Kanayannur Taluk, wherein it is certified that the petitioner does not belong to the creamy layer mentioned in Column 3 of the Schedule to the Government of India, the Department of Personnel and Training O.M.No.36012/22/93-Estt.(SCT) dated 08.09.1993. Ext.P3 is a copy of the hall ticket issued to the petitioner, with application No.26IAT050945 and Roll No.IAT00315050945, of IISER Aptitude Test - 2026 scheduled on 07.06.2026. As per Ext.P4 IAT 2026 rank details, the petitioner secured overall rank - 4281 and category rank - 955. In Ext.P4, it is specified that the category rank is provisional and subject to change based on verification of the documents in the document upload window.

In paragraph 6 of the statement of facts, the petitioner has stated that she submitted Ext.P2 non-creamy layer certificate without knowing that the non-creamy layer certificate, which is valid for the financial year 2026-27 and issued on or after 01.04.2026, alone would be considered, as stipulated in clause 6 of Ext.P1 information brochure. Immediately upon coming to know about the said rule, the petitioner obtained Ext.P5 non-creamy layer certificate dated 08.07.2026 issued by the Tahsildar, Kanayannur Taluk, which is valid for the financial year 2026-27 and issued on or after 01.04.2026. Since the petitioner was unable to upload Ext.P5 non-creamy layer certificate, her father sent Ext.P6 e-mail on 26.07.2026 to the Joint Admission Committee, enclosing therewith a copy of Ext.P5 non-creamy layer certificate.

In response to Ext.P6 e-mail, the petitioner’s father received Ext.P7 e-mail dated 26.07.2026, wherein it is stated that, as per the admission policy, candidates are considered under their declared reserved category only if a valid category certificate was uploaded on the application portal by the prescribed deadline. The petitioner’s father sent Ext.P8 e-mail on 28.07.2026, stating that the petitioner inadvertently missed to upload the latest OBC-NCL certificate and therefore, the latest OBC-NCL may be considered for the admission process. In response to Ext.P8 e-mail, the petitioner’s father received Ext.P9 e-mail dated 29.07.2026, which is addressed to the petitioner, whereby she was informed that her application for consideration under OBC-NCL category has been rejected and her application has been considered under unreserved (UR)/general category, since she failed to submit (through the application portal) a valid category certificate as per the instructions given in the information brochure, for consideration under OBC-NCL category, before the last date of 21.06.2026 specified in the information brochure issued in March, 2026.

In W.P.(C)No.26238 of 2026, the 3^rd respondent Joint Admission Committee - 2026, the appellant herein, filed a counter affidavit dated 06.08.2026, opposing the reliefs sought for, producing therewith a copy of IISER Aptitude Test (IAT) - 2026 information brochure along with syllabi for IAT - 2026 and Annexure thereto, which contains the formats of certificates and forms, as Ext.R3(a). A copy of the said information brochure, without syllabi for IAT - 2026 and the Annexure thereto, has been marked as Ext.P1 in the writ petition. The document marked as Ext.R3(b) is a copy of an office memorandum issued by the Government of India, Ministry of Personnel, Public Grievances and Pensions, Department of Personnel and Training, Establishment Reservation-I Section, F.No.36036/2/2013-Estt.(Res-I) dated 31.03.2016, on the subject ‘validity period of OBC certificate in respect of creamy layer status of the candidates'. In the counter affidavit, it is stated that the information brochure clearly states that all disputes are subject to the jurisdiction of the courts at Odisha. In the counter affidavit, it is contended that the 1^st respondent Union of India, represented by the Secretary to Government, Ministry of Education and the 2^nd respondent Secretary, the Department of Higher Education, have been wrongly impleaded in the writ petition only to create territorial jurisdiction before this Court, though no reliefs have been sought against the said respondents, who have no role whatsoever in the writ petition. Therefore, the writ petition is not maintainable before this Court.

In the counter affidavit, it is pointed out that, as per Ext.R3(b) office memorandum dated 31.03.2016, OBC-NCL certificate is valid only till 31^st March following the date of issue of the certificate. Ext.P2 OBC-NCL certificate submitted by the petitioner along with her application, which was dated 09.02.2026, expired on 31.03.2026, and could not be considered after the date of expiry. Therefore, Ext.P2 OBC-NCL certificate submitted by the petitioner was not in terms of the conditions specified in Ext.R3(a) information brochure. The candidates were clearly informed of the terms and conditions applicable to OBC-NCL certificates at various places in Ext.R3(a) information brochure, the details of which are furnished in paragraph 8 of the counter affidavit. Therefore, the petitioner had complete knowledge of the requirements of OBC-NCL certificate from the information brochure. The petitioner failed to submit a valid OBC-NCL certificate before the cut-off date of 21.06.2026, in violation of the terms and conditions in the information brochure. Consequently, her application for consideration under OBC-NCL category has been rightly rejected.

In the counter affidavit, it is stated that any concession from this Court would create chaos in the admission process by the Joint Admission Committee. The Committee has received approximately 1.3 lakh applications. In approximately 500 cases, the candidates were unable to submit a valid OBC-NCL certificate for one reason or the other. The scrutiny of the documents is already over, and offer letters have been issued to the successful candidates, who have also acted on them. Any reversal of the process would create many problems not only to the Joint Admission Committee but also to the successful candidates. Any concession by this Court in the present case would be counterproductive to the interests of the candidates who have carefully gone through the information brochure and complied with the terms and conditions contained therein. In paragraphs 11 to 31 of the counter affidavit, the 3^rd respondent Joint Admission Committee has dealt with the averments in the statement of facts and grounds of W.P.(C)No.26238 of 2026.

W.A.No.1702 of 2026:- The 1^st respondent in this writ appeal, who applied for IISER Aptitude Test (IAT) - 2026, in furtherance of the information brochure published by the Joint Admission Committee – 2026, the appellant herein, for admission to 5-year BS-MS (Dual Degree), 4-year BS and B.Tech Degree Programs – 2026 in the IISERs, filed W.P.(C)No.27028 of 2026, aggrieved by non-consideration of Ext.P1 non-creamy layer certificate, which was uploaded along with her application for getting admission to five-year BS-MS (Dual Degree) Program -2026, on the ground that the certificate uploaded by her was not issued in the financial year 2026-27. In the writ petition, the petitioner sought for a writ of certiorari to quash Ext.P10 e-mail communication dated 29.07.2026 issued by the 2^nd respondent (appellant herein), whereby the petitioner was informed that her candidature for selection under OBC-NCL category has been rejected, since she failed to submit a valid category certificate as per the information brochure, before the last date of 21.06.2026 specified therein, which was issued in March, 2026. The reliefs sought for in W.P.(C)No.27028 of 2026 read thus;

In W.P.(C)No.27028 of 2026, the document marked as Ext.P1 is a copy of non-creamy layer certificate dated 13.01.2026 issued by the Tahsildar, Kozhikode Taluk, wherein it is certified that the petitioner does not belong to the creamy layer mentioned in Column 3 of the Schedule to the Government of India, the Department of Personnel and Training O.M.No.36012/22/93-Estt. (SCT) dated 08.09.1993. The document marked as Ext.P2 is a printout of the application made by the petitioner for IISER Aptitude Test - 2026. Ext.P3 is a copy of the hall ticket issued to the petitioner with application No.26IAT084750 and roll No. IAT08836084750 of IISER Aptitude Test - 2026 scheduled on 07.06.2026. On 17.06.2026, the petitioner received Ext.P4 e-mail, whereby she was required to go to IISER admission portal and update documents as required. The e-mail states that the document upload window will be closed on 21.06.2026 at 11.55 p.m. Since the petitioner did not receive an updated OBC-NCL certificate, though she applied on 18.06.2026, she again uploaded Ext.P1 OBC-NCL certificate. Though the petitioner received Ext.P5 updated OBC-NCL certificate on 22.06.2026, she could not upload the same, since the deadline was over on 21.06.2026. She sent Ext.P6 e-mail to the Joint Admission Committee on 29.06.2026, enclosing therewith a copy of Ext.P5 certificate. Thereafter, on 03.07.2026, she made Ext.P7 submission on the web portal. As per Ext.P8 IAT 2026 rank details, the petitioner secured overall rank - 7117 and category rank - 1701. In Ext.P8, it is specified that the category rank is provisional and subject to change based on the verification of the documents in the document upload window. Since the allotment process was started on 24.07.2026, the petitioner sent Ext.P9 e-mail on 28.07.2026, with a request to confirm whether she is being considered under OBC-NCL category. On 29.07.2026, the petitioner received Ext.P10 e-mail, whereby she was informed that her application for consideration under OBC-NCL category has been rejected and her application has been considered under unreserved (UR)/general category, since she failed to submit (through the application portal) a valid category certificate as per the instructions given in the information brochure, entitling consideration under OBC-NCL category, before the last date of 21.06.2026 specified in the information brochure issued in March, 2026. Ext.P11 is a copy of closing ranks in the first round of counselling, and Ext.P12 is the relevant extract of IISER Aptitude Test - 2026 information brochure.

In W.P.(C)No.27028 of 2026, the 2^nd respondent Joint Admission Committee - 2026, the appellant herein, filed a counter affidavit dated 07.08.2026, opposing the reliefs sought for, producing therewith a copy of IISER Aptitude Test (IAT) - 2026 information brochure along with syllabi for IAT - 2026 and Annexure to the information brochure which contains the formats of certificates and forms, as Ext.R2(a). Ext.R2(b) is a copy of a declaration given by the petitioner on 18.06.2026, in lieu of OBC-NCL certificate. Ext.R2(c) is a copy of an office memorandum issued by the Government of India, Ministry of Personnel, Public Grievances and Pensions, Department of Personnel and Training, Establishment Reservation-I Section F.No.36036/2/2013-Estt. (Res-I) dated 31.03.2016 on the subject ‘validity period of OBC certificate in respect of creamy layer status of the candidates’.

In the counter affidavit, it is stated that the information brochure clearly states that all disputes are subject to the jurisdiction of the courts at Odisha. The 1^st respondent Union of India, represented by the Secretary to Government, Ministry of Education and the 3^rd respondent Indian Institute of Science Education and Research, Thiruvananthapuram, represented by its Secretary, have been wrongly impleaded in the writ petition only to create territorial jurisdiction before this Court, though no reliefs have been sought against the said respondents, who have no role whatsoever in the writ petition. Therefore, the writ petition is not maintainable before this Court.

In the counter affidavit, it is pointed out that, as per Ext.R2(c) office memorandum dated 31.03.2016, OBC-NCL certificate is valid only till 31^st March following the date of issue of the certificate. Ext.P1 OBC-NCL certificate submitted by the petitioner along with her application, which was dated 13.01.2026, expired on 31.03.2026, and could not be considered after the date of expiry. Therefore, Ext.P1 OBC-NCL certificate submitted by the petitioner was not in terms of the conditions specified in Ext.R2(a) information brochure. The candidates were clearly informed of the terms and conditions applicable to OBC-NCL certificates at various places in Ext.R2(a) information brochure, the details of which are furnished in paragraph 10 of the counter affidavit. Therefore, the petitioner had complete knowledge of the requirements of OBC-NCL certificate from the information brochure. The petitioner failed to submit a valid OBC-NCL certificate before the cut-off date of 21.06.2026, in violation of the terms and conditions in the information brochure. Consequently, her application for consideration under OBC-NCL category has been rightly rejected. In the writ petition, the petitioner intentionally concealed Ext.R2(b) undertaking given by her on 18.06.2026. This clearly shows that the petitioner has not approached this Court with clean hands. The petitioner is bound by the undertaking given in Ext.R2(b).

In the counter affidavit, it is stated that any concession from this Court would create chaos in the admission process by the Joint Admission Committee. The Committee has received approximately 1.3 lakh applications. In approximately 500 cases, the candidates were unable to submit a valid OBC-NCL certificate for one reason or the other. The scrutiny of the documents is already over, and offer letters have been issued to the successful candidates, who have also acted on them. Any reversal of the process would create many problems not only to the Joint Admission Committee but also to the successful candidates. Any concession by this Court in the present case would be counterproductive to the interests of the candidates who have carefully gone through the information brochure and complied with the terms and conditions contained therein. In paragraphs 13 to 36 of the counter affidavit, the 2^nd respondent Joint Admission Committee has dealt with the averments in the statement of facts and grounds of W.P.(C)No.27028 of 2026.

After considering the rival contentions, the learned Single Judge, by the impugned judgment dated 13.08.2026, allowed W.P.(C)Nos.26238 of 2026 and 27028 of 2026 to the extent indicated in that judgment. The learned Single Judge held that since the petitioners submitted their applications from Kerala, the rejection of their applications was received in Kerala and the documents claiming the benefit of OBC-NCL category were also submitted from Kerala, certainly a fraction of the cause of action has arisen in Kerala, entitling this Court to consider those writ petitions. Paragraphs 6 to 10 of the judgment dated 13.08.2026 of the learned Single Judge read thus;

Adverting to the merits of the contentions raised in the writ petitions, after referring to clauses 6 and 13 of IISER Aptitude Test - 2026 information brochure, and taking note of the law laid down by the Apex Court in Dolly Chhanda v. Chairman, Joint Entrance Examination (JEE) [(2005) 9 SCC 779] and Ram Kumar Gijroya v. Delhi Subordinate Services Selection Board [(2016) 4 SCC 754], the learned Single Judge held that the initial certificates submitted by both the petitioners revealed that those certificates were stated to be valid for a period of one year from the date of issue, and obviously the validity period mentioned in those certificates covered the date fixed in the information brochure as well as the cut-off date, i.e., 21.06.2026. On being informed of the stipulation to produce a certificate issued on or after 01.04.2026, the petitioners submitted such certificates as well, though beyond the cut-off date. Therefore, the petitioners’ claim to be included in OBC-NCL category remained valid at the time of submitting the applications and during the admission process. In such circumstances, rigid adherence to the stipulation of a certificate to be submitted on or before 21.06.2026, in the case of the petitioners, is arbitrary and unreasonable. Thus, the petitioners ought to be considered to fall within the OBC-NCL category, based on the certificates produced as Exts.P2 and P5 in W.P.(C)No.26238 of 2026 and Exts.P1 and P5 in W.P.(C)No.27028 of 2026. Consequently, the learned Single Judge quashed Ext.P9 communication in W.P.(C)No.26238 of 2026 and Ext.P10 communication in W.P.(C)No.27028 of 2026 of the Joint Admission Committee and the respondents therein were directed to consider the petitioners as falling in the OBC-NCL category, based on the certificates already produced by them. Paragraphs 11 to 19 and also the last paragraphs of the impugned judgment dated 13.08.2026 of the learned Single Judge read thus;

On 03.09.2026, we heard arguments of Adv. Shireesh Gupta, the learned counsel for the appellant-3^rd respondent in W.A.No.1701 of 2026 and the learned counsel for the appellant-2^nd respondent in W.A.No.1702 of 2026, Adv. D. Kishore, the learned counsel for the 1^st respondent-petitioner in W.A.No.1701 of 2026, Adv. Suvin R. Menon, the learned Senior Panel Counsel for respondents 2 and 3 in that writ appeal, Adv. P.K. Mohamed Jameel, the learned counsel for the 1^st respondent-petitioner in W.A.No.1702 of 2026, Adv. Suvin R. Menon, the learned Senior Panel Counsel for the 2^nd respondent and Adv. Helen P.A., the learned Standing Counsel for the Indian Institute of Science Education and Research (IISER), Thiruvananthapuram, for the 3^rd respondent in that writ appeal. The learned Senior Panel Counsel for the Union of India and the learned Standing Counsel for the Indian Institute of Science of Education and Research pointed out that the Union of India and IISER, Thiruvananthapuram, are only formal parties.

The learned counsel for the appellant-Joint Admission Committee argued that the judgment dated 13.08.2026 of the learned Single Judge in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 is opposed to law and facts of the case. In the impugned judgment, the learned Single Judge did not interfere with the requirements in the information brochure for IISER Aptitude Test - 2026 that the OBC-NCL certificate issued should be valid for the financial year 2026-27, and issued on or after 01.04.2026; and that the candidate has to upload such certificate on or before 21.06.2026. Without interfering with the above requirements in the information brochure, the learned Single Judge directed the appellant Joint Admission Committee to consider the petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 as falling under OBC-NCL category, based on Exts.P2 and P5 certificates in W.P.(C)No.26238 of 2026 and Exts.P1 and P5 certificates in W.P.(C)No.27028 of 2026. The direction issued by the learned Single Judge, without interfering with the above requirements in the information brochure, is per se arbitrary and illegal.

The learned counsel for the appellant argued that the learned Single Judge failed to consider the decision of a Division Bench of the Punjab and Haryana High Court in Yoshika Verma v. Union of India [2022 SCC OnLine P&H 3760] - judgment dated 17.05.2022 in CWP No.3435 of 2022 - rendered after taking note of the decision of the Apex Court in Dolly Chhanda [(2005) 9 SCC 779]. SLP(C)No.11464 of 2022 filed before the Apex Court against the said judgment ended in dismissal by the order dated 22.07.2022. The learned Single Judge completely ignored the specific contention raised in paragraph 8 of the counter affidavit in W.P.(C)No.26238 of 2026 and paragraph 10 of the counter affidavit in W.P.(C)No.27028 of 2026 that the candidates were clearly informed of the terms and conditions applicable to OBC-NCL certificates at various places in Ext.R3(a)/R2(a) information brochure.

The learned counsel for the appellant pointed out that, in W.P.(C)No.27028 of 2026, the petitioner intentionally concealed Ext.R2(b) undertaking given by her on 18.06.2026, in lieu of OBC-NCL certificate, issued on or after 01.04.2026, as per the requirements of clause 13 of the information brochure, who had also undertaken to upload OBC-NCL certificate on or before 21.06.2026, failing which she will not be considered for admission under OBC-NCL category. This clearly shows that the petitioner in that writ petition has approached this Court with unclean hands, suppressing material facts. The learned Single Judge completely ignored the specific contention raised in paragraph 7 of the counter affidavit filed in W.P.(C)No.27028 of 2026 regarding suppression of material facts. The learned counsel pointed out further that the petitioner in W.P.(C)No.26238 of 2026, who failed to upload OBC-NCL certificate issued on or after 01.04.2026, as per the requirements of clause 13 of the information brochure, has not even chosen to give any such undertaking. The submission of the learned counsel for the appellants is that the petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026, who failed to submit a valid OBC-NCL certificate before the cut-off date of 21.06.2026, in violation of the terms and conditions in the information brochure, are not legally entitled to have their applications considered under OBC-NCL category. As provided in clause 13 of the information brochure, they will be considered for admission only under the unreserved (UR)/general category.

The learned counsel for the appellant argued that the learned Single Judge failed to note that any concession from the Court would create chaos in the admission process. The Joint Admission Committee received approximately 1.3 lakh applications. In approximately 1000 cases, candidates could not submit a valid OBC-NCL certificate for one reason or another. After scrutinising the documents, the Committee issued offer letters to the successful candidates, who have also acted on them. Reversing the process would create many problems not only for the Committee but also for the successful candidates. The Committee is working against an extremely tight admission schedule. The classes have to start by the first week of October, 2026, to complete the syllabus. The schedule leaves a very narrow window to complete the admission process. Therefore, the impugned judgment of the learned Single Judge cannot be sustained in law. The learned counsel also argued that, as contended in the counter affidavits filed in W.P.(C)Nos.26238 of 2026 and 27028 of 2026, this Court lacks territorial jurisdiction to entertain the writ petitions. The learned counsel pointed out a subsequent judgment of the learned Single Judge in Devanjana S. Narayanan v. Indian Institute of Science Education and Research [2026:KER:66043], whereby the prayer sought in W.P.(C)No.27313 of 2026 for directing the respondents therein to grant admission to the petitioner therein under OBC-NCL category was declined; however, it was ordered that, if in the event of any seat falling vacant at the end of the process of allotment, necessarily the respondents shall consider the petitioner under OBC-NCL category, based on the certificate dated 06.08.2026 already submitted.

On the other hand, the learned counsel for the 1^st respondent in the respective writ appeals contended that the impugned judgment dated 13.08.2026 of the learned Single Judge in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 is one rendered after taking note of the legal and factual contentions raised by both sides. The reasoning of the learned Single Judge in the impugned judgment, which is neither perverse nor patently illegal, warrants no interference in this writ appeal. On a proper appreciation of the facts and circumstances of the case, in the light of the law on the point, the learned Single Judge arrived at a finding that the claim of the petitioner in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 for inclusion in OBC-NCL category continued to remain valid at the time of submission of the applications as well as at the time of the admission process. Hence, a rigid adherence to the stipulation that a certificate be submitted on or before 21.06.2026, in their case, is arbitrary and unreasonable. Ext.P2 certificate dated 09.02.2026 in W.P.(C)No. 26238 of 2026 and Ext.P1 certificate dated 13.01.2026 in W.P.(C)No.27028 of 2026, i.e., the OBC-NCL certificates originally uploaded, are valid for a period of one year from the date of issuance. As in the case of those OBC-NCL certificates, in Ext.P5 certificate dated 08.07.2026 in W.P.(C)No.26238 of 2026 and Ext.P5 certificate dated 22.06.2026 in W.P.(C)No.27028 of 2026, it is certified that the petitioner in the respective writ petitions does not belong to the creamy layer mentioned in Column 3 of the Schedule to the Government of India, the Department of Personnel and Training O.M.No.36012/22/93-Estt.(SCT) dated 08.09.1993. Therefore, the learned Single Judge rightly concluded that the petitioner in both the writ petitions ought to be considered as falling in the OBC-NCL category based on Exts.P2 and P5 certificates in W.P.(C)No.26238 of 2026 and Exts.P1 and P5 certificates in W.P.(C)No.27028 of 2026.

The learned counsel for the 1^st respondent in W.A.No.1701 of 2026 referred to the provisions contained in Article 46 of the Constitution of India, which provides for the promotion of educational and economic interests of Scheduled Castes, Scheduled Tribes and other weaker sections. The submission of the learned counsel for the appellant that the Joint Admission Committee is working against an extremely tight admission schedule since the classes have to be started by the first week of October, 2026, for the purpose of completing the syllabus, is not a valid ground to deny admission to meritorious candidates, in view of the law laid down by the Apex Court in S. Krishna Sradha v. State of A.P. [(2020) 17 SCC 465]. The learned counsel for the 1^st respondent in the respective writ appeals contended that the finding of the learned Single Judge in the impugned judgment, on the territorial jurisdiction of this Court to entertain a writ petition under Article 226 of the Constitution of India, is one made after referring to the law on the point, which is perfectly legal. Therefore, no interference is warranted on the impugned judgment of the learned Single Judge in this writ appeal.

The appellant Joint Admission Committee-2026 conducted IISER Aptitude Test (IAT) - 2026 on 07.06.2026, for admission to 5-year BS-MS (Dual Degree), 4-year BS and B.Tech Degree Programs - 2026 in IISERs established by the Government of India at Berhampur, Bhopal, Kolkata, Mohali, Pune, Thiruvananthapuram and Tirupati in furtherance of Ext.P1 information brochure in W.P.(C)No.26238 of 2026. The information brochure along with syllabi for IAT - 2026 and Annexure to the information brochure which contains formats of certificates and forms is marked as Ext.R3(a) along with the counter affidavit in W.P.(C)No.26238 of 2026 and as Ext.R2(a) along with the counter affidavit in W.P.(C)No.27028 of 2026.

Clause 4 of Ext.R3(a) information brochure for IISER Aptitude Test (IAT) – 2026, hereinafter referred to as ‘information brochure’, deals with the procedure of admission. As per clause 4, IISER Aptitude Test (IAT) - 2026 is the only channel of admission. Candidates must strictly follow the instructions given in the information brochure and on the IAT website (www.iiseradmission.in). Applications not complying with the instructions shall be summarily disqualified.

Clause 6 of the information brochure deals with reservation of seats. As per clause 6, reservation policies as mandated by the Government of India will apply. The criteria for OBC-NCL will be as per the Government of India notification. Candidates belonging to the creamy layer of OBC are not entitled to reservation. Such candidates are treated as belonging to the General (GEN), i.e., unreserved category, and they will be eligible only for the open seats - the seats for which all candidates are eligible. EWS/OBC-NCL certificate should be issued by the Government of India, valid for the financial year 2026-27, and issued on or after 01.04.2026.

Clause 13 of the information brochure deals with documents required for application. As per clause 13, scanned copies of the documents/certificates listed below clause 13 are to be uploaded at the time of online application for IAT - 2026. The formats of some certificates, as prescribed by the Government of India, are given in the Annexures. As per clause 13, for candidates seeking admission under the OBC-NCL category, the OBC-NCL certificate should have been issued on or after 01.04.2026, as per the latest guidelines of the Government of India. If any OBC-NCL candidate fails to submit the OBC-NCL certificate (issued on or after 01.04.2026) at the time of online application, the candidate must upload a signed declaration form in lieu of the OBC-NCL certificate. The candidate has to upload a certificate issued on or after 01.04.2026, on or before 21.06.2026. Failing which, the candidate will not be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category. The relevant provisions of clause 13, which deal with candidates seeking admission under the OBC-NCL category, read thus;

In the Annexure to the information brochure, ‘FORM-OBC-NCL’ is the format of the OBC-NCL certificate, which is extracted hereunder;

The format of declaration by the candidate in lieu of OBC-NCL certificate in the Annexure to the information brochure is extracted hereunder;

Clause 16 of the information brochure deals with important dates. In clause 16, 21.06.2026 is specified as the last date for uploading selective information/document in the application form. Clause 26 deals with important conditions. As per clause 26, the candidate will be solely and entirely responsible for the authenticity of the information and documents submitted by the individual. At any time during or after the process of admission, if it is found that a candidate is ineligible for admission as per the prescribed rules, the candidate’s admission or candidature will be cancelled immediately. Upon submission of the application, the candidates are deemed to have agreed and accepted all the terms and conditions stipulated in the brochure. The candidate shall not be entitled to seek exemption/variation/ alteration of any condition.

As per clause 26 of the information brochure, candidates are required to carefully read and understand the contents of this brochure. In case of any doubt, the applicants may seek clarification before the submission of their application in advance. Requests for clarification will not be entertained after the deadlines for application submission and document upload. Candidates are required to carefully scrutinise and verify every document being submitted with the application as also the application itself. The candidate is entirely and solely responsible for the correctness of these documents/application, for any mistakes in these documents/application and for any missing/ wrong documents. The candidate is also required to ensure that all the required documents are submitted on or before the cut-off date(s). At any time during or after the process of admission, if it is found that a candidate is ineligible for admission as per the prescribed rules, the candidate’s admission or candidature will be cancelled immediately.

In paragraph 8 of the counter affidavit filed in W.P.(C)No.26238 of 2026 and paragraph 10 of the counter affidavit filed in W.P.(C)No.27028 of 2026, the appellant Joint Admission Committee specifically pointed out, with specific reference to various clauses in the information brochure, that the candidates were clearly informed of the terms and conditions applicable to OBC-NCL certificates. The details furnished in paragraph 8 of the counter affidavit filed in W.P.(C)No.26238 of 2026 read thus;

However, the learned Single Judge has not dealt with the specific contentions raised in this regard in paragraph 8/10 of the counter affidavits filed by the Joint Admission Committee, while rendering the impugned judgment.

Office Memorandum F.No.36036/2/2013-Estt.(Res-I) dated 31.03.2016 issued by the Government of India, Ministry of Personnel, Public Grievances and Pensions, Department of Personnel and Training, Establishment Reservation-I Section, on the subject ‘validity period of OBC certificate in respect of creamy layer status of the candidates', is marked as Ext.R3(b) along with the counter affidavit filed in W.P.(C)No.26238 of 2026 and as Ext.R2(c) along with the counter affidavit filed in W.P.(C)No.27028 of 2026. The argument of the learned counsel for the appellant Joint Admission Committee is that every candidate seeking reservation in admission as an OBC candidate is required to submit a certificate confirming his/her status as OBC and also Non-Creamy Layer (NCL) status issued by the authority mentioned in the DOPT Office Memorandum No.36012/22/93-Estt.(SCT) dated 15.11.1993. NCL would be applicable to OBC candidates who are covered under the income/wealth test criterion. The income limit is determined by the income earned in the three previous financial years preceding the year of admission. The validity of NCL issued during any month of a financial year, covering three preceding financial years, would be from April to March of that financial year. On the above aspect, the argument of the learned counsel for the 1^st respondent-petitioner in the writ appeals is that, as in the case of OBC-NCL certificates originally uploaded at the time of submission of online application, in Ext.P5 certificate dated 08.07.2026 in W.P.(C)No. 26238 of 2026 and Ext.P5 certificate dated 22.06.2026 in W.P.(C)No.27028 of 2026, it is certified that the petitioners do not belong to the creamy layer mentioned in Column 3 of the Schedule to the Government of India, the Department of Personnel and Training O.M.No.36012/22/93-Estt.(SCT) dated 08.09.1993.

As per clause 6 of the information brochure, the criteria for OBC-NCL will be as per the Government of India notification. OBC-NCL certificate should be issued by the Government of India, valid for the financial year 2026-27, and issued on or after 01.04.2026. As per clause 13, for candidates seeking admission under the OBC-NCL category, the OBC-NCL certificate should have been issued on or after 01.04.2026, as per the latest guidelines of the Government of India. If any OBC-NCL candidate fails to submit the OBC-NCL certificate (issued on or after 01.04.2026) at the time of online application, the candidate must upload a signed declaration form in lieu of the OBC-NCL certificate. The candidate has to upload a certificate issued on or after 01.04.2026, on or before 21.06.2026. Failing which, the candidate will not be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category. In paragraphs 11 and 12 of the impugned judgment, the learned Single Judge has referred to clauses 6 and 13 of the information brochure.

In paragraph 13 of the impugned judgment, the learned Single Judge observed that a reading of clauses 6 and 13 in the information brochure reveals that the requirement of a certificate issued on or after 01.04.2026 has been specifically detailed not only in bold letters in the note to clause 6, but again in clause 13 relating to documents required for the application. The above stipulations have been followed by numerous students, all of whom would have submitted their applications. Similarly, several other applicants would not have been able to submit their applications as stipulated and would have been refused consideration under the reserved category OBC-NCL. Though the petitioners in both writ petitions assert that they had subsequently submitted certificates issued after 01.04.2026, certifying them as falling within the category OBC-NCL, those certificates were issued and submitted after 21.06.2026, the cut-off date for production of certificates.

In Dolly Chhanda [(2005) 9 SCC 779], the decision relied on by the learned counsel for the 1^st respondent-petitioner in both the writ appeals, a Three-Judge Bench of the Apex Court was dealing with a case relating to admission to MBBS course, based on the rank secured in the Joint Entrance Examination (JEE) – 2003, under reserved category, being a daughter of an ex-service man. In the said decision, the Apex Court observed that, the general rule is that while applying for any course of study or a post, a person must possess the eligibility qualification on the last date fixed for such purpose either in the admission brochure or in application form, as the case may be, unless there is an express provision to the contrary. There can be no relaxation in this regard, i.e., in the matter of holding the requisite eligibility qualification by the date fixed. This has to be established by producing the necessary certificates, degrees or marksheets. Similarly, in order to avail of the benefit of reservation or weightage, etc., necessary certificates have to be produced. These are documents in the nature of proof of holding of particular qualification or percentage of marks secured or entitlement to benefit of reservation. Depending upon the facts of a case, there can be some relaxation in the matter of submission of proof, and it will not be proper to apply any rigid principle as it pertains to the domain of procedure. Every infraction of the rule relating to submission of proof need not necessarily result in rejection of candidature.

In Dolly Chhanda [(2005) 9 SCC 779], the appellant before the Apex Court, who passed 10+2 (Science) examination conducted by the Council of Higher Secondary Education, Orissa, in first class, who was desirous of joining medical course, appeared in the Joint Entrance Examination (JEE) - 2003 under the reservation provided in clause 2.1.4. of the information brochure, being the daughter of an ex-serviceman. Though she was ranked 20 in the reserved category in the medical stream and called for counselling on 07.07.2003, during the course of scrutiny of documents, it was found that in the certificate dated 29.06.2003 given to her father by the Zilla Sainik Board, in column 3 which pertained to ‘disabled/killed in war/ hostilities’ the words ‘not eligible’ were written. Since the said certificate did not satisfy the requirement of the reserved category, her candidature was rejected. The appellant's father then requested the Zilla Sainik Board, Sambalpur, to rectify the mistake, which issued a fresh certificate on 16.07.2003 which mentioned ‘permanently disabled’ in column 3. Though the appellant produced the correct certificate, no action was taken. The case of the appellant was that it was the Zilla Sainik Board which had committed the mistake in not issuing a correct certificate and the said mistake having been rectified in the second certificate issued on 16.07.2003, hence she was entitled to admission in a medical college, as candidates who secured lower ranks had already been admitted.

In Dolly Chhanda [(2005) 9 SCC 779], the Three-Judge Bench has referred to the decision of a Two-Judge Bench in Charles K. Skaria v. Dr. C. Mathew [(1980) 2 SCC 752], where the controversy related to admission to a postgraduate course in medicine. The relevant rule provided for the addition of 10% marks if a candidate possessed a diploma in the relevant subject or subspecialty and this benefit could be given only if the candidate's success in the diploma course was brought to the knowledge of the Selection Committee before completion of selection in an authentic or acceptable manner. The prospectus provided that the attested copies of statement of marks and other documents should be attached with every application. Three such candidates were given admission, who had not attached the certificate of having passed the diploma along with their applications. Their admission to postgraduate courses was set aside by the High Court on the ground that their applications, wherein they claimed the benefit of diploma, were liable to be rejected, as the requisite certificates had not been attached. The Two-Judge Bench reversed the judgment of the High Court and held that the admission to the candidates had rightly been given, as they had in fact passed the diploma before the date fixed.

In Dolly Chhanda [(2005) 9 SCC 779], on the facts of the case at hand, the Three-Judge Bench noted that the appellant undoubtedly belonged to reserved category, being the daughter of an ex-service man. She comes from a very humble background, and her father was only a Naik in the armed forces, who may not have noticed the mistakes which had been committed by the Zilla Sainik Board while issuing the first certificate dated 29.06.2003. But it does not mean that the appellant should be denied admission, when she produced a correct certificate at the stage of second counselling. Those who secured rank lower than the appellant have already been admitted. Therefore, the Three-Judge Bench held that the view taken by the authorities in denying admission to the appellant is wholly unjust and illegal. Since the academic year for JEE – 2003 was already over, the Apex Court directed the respondents to give admission to the appellant for MBBS course in any of the State Medical Colleges during the academic year 2004, if found necessary, after creating one extra seat.

In the impugned judgment, after referring to the law laid down by the Apex Court in Dolly Chhanda [(2005) 9 SCC 779], the learned Single Judge observed that the law laid down by the Apex Court indicates that in the matter of submission of proof of eligibility based on qualification, there can be no relaxation, while in the matter of claim of reservation, there can be some relaxation, depending on the facts of each case, as it is a matter of submission of proof, and hence falls in the domain of procedure. On the facts of the case at hand, the learned Single Judge observed that both petitioners had, along with their application, submitted documents showing that they belonged to the OBC-NCL category, but those certificates were issued prior to the date fixed in the information brochure, i.e., 01.04.2026. As per the stipulation in the information brochure, they should have submitted certificates issued on or after 01.04.2026. Later, both petitioners also submitted such certificates. However, those certificates were issued and submitted beyond the cut-off date of 21.06.2026.

In the impugned judgment, after referring to the decision of the Apex Court in Ram Kumar Gijroya [(2016) 4 SCC 754], the learned Single Judge observed that, at the time of publishing the results, the petitioners were categorised as falling in the OBC-NCL category. Therefore, all that remains is a cross-verification of whether they continue to remain in the OBC-NCL category, as stipulated in the information brochure, on the date of admission. It is evident from the rank certificates that both petitioners have been considered and included in the OBC-NCL category. The inclusion is, of course, subject to document verification. Certainly, it is a matter that falls in the domain of procedure as to whether the claim of eligibility and the categorisation of the petitioners by IISER itself, as falling in the OBC-NCL category, is justified or not. Therefore, according to the learned Single Judge, the rigid stipulation of production of the NCL certificate on or before 21.06.2026, in the circumstances, requires relaxation, as observed by the Apex Court in Dolly Chhanda [(2005) 9 SCC 779].

In Ram Kumar Gijroya [(2016) 4 SCC 754], a Two-Judge Bench of the Apex Court was dealing with a case in which the appellant submitted an application for selection to the post of Staff Nurse in the Department of Health and Family Welfare, Government of NCT of Delhi, pursuant to a notification dated 30.08.2007 published by the Delhi Subordinate Services Selection Board. The last date of submission of application was 21.01.2008. Having appeared in the examination, the appellant was shortlisted for selection. However, his name did not appear in the final list of selected candidates, for the reason that he had failed to submit the OBC certificate issued by the appropriate authority along with the application form, before the last date of submission of application. The appellant applied for OBC certificate only ten days prior to the cut-off date. The contention on behalf of Delhi Subordinate Services Selection Board was that the High Court was justified in not allowing the appellant to submit the OBC certificate after the cut-off date fixed in the advertisement, as he had failed to submit the required certificate for availing the benefit of reservation, within the stipulated time, and thus, he had waived his right for being considered under the reserved category.

In Ram Kumar Gijroya [(2016) 4 SCC 754], after considering the rival contentions, the Two-Judge Bench found that the Division Bench of the High Court erred in not considering the decision rendered in Pushpa v. Government of NCT of Delhi [2009 SCC OnLine Del 281], wherein the learned Single Judge of the High Court had rightly held that petitioners therein were entitled to submit OBC certificate before the provisional selection list was published to claim the benefit of the reservation of OBC category. The Two-Judge Bench noticed that the learned Single Judge correctly examined the entire situation not in a pedantic manner but in the backdrop of the object of reservations made to the reserved categories, and keeping in view the law laid down by a Constitution Bench in Indra Sawhney v. Union of India [(1992) Supp (3) SCC 217] as well as Valsamma Paul v. Cochin University [(1996) 3 SCC 545].

As already noticed hereinbefore, in Dolly Chhanda [(2005) 9 SCC 779], the Three-Judge Bench was dealing with a case in which the claim of the appellant for reservation, as provided under clause 2.1.4. of the information brochure of JEE – 2003, was under the reserved category, being the daughter of an ex-service man. In the certificate dated 29.06.2003 originally issued by the Zilla Sainik Board, by mistake, the words ‘not eligible’ were written in column 3 which pertained to ‘disabled/ killed in war/hostilities’. The said mistake was corrected and a corrected certificate dated 16.07.2003 was obtained. Similarly, in Charles K. Skaria [(1980) 2 SCC 752], the Two-Judge Bench was dealing with a case in which the relevant rule for admission to postgraduate course in medicine provided for the addition of 10% marks if the candidate possessed a diploma in the relevant subject or subspecialty and the success in the diploma course was brought to the knowledge of the selection committee before completion of selection in an authentic and acceptable manner. In the said case, the admission given to three candidates was set aside by the High Court, since they have not attached the certificate of passing the diploma along with their applications. In Ram Kumar Gijroya [(2016) 4 SCC 754], the Two-Judge Bench was dealing with a case in which the claim made by the appellant for selection to the post of Staff Nurse in the Department of Health and Family Welfare, Government of NCT of Delhi, was rejected for the reason that he had failed to submit the OBC certificate issued by the appropriate authority along with the application form, before the last date of submission of application. The Two-Judge Bench noted that as held by a learned Single Judge of the High Court in Pushpa [2009 SCC OnLine Del 281], to claim the benefit of reservation of OBC category, candidates are entitled to submit OBC certificate before the provisional selection list was published.

In Yoshika Verma [2022 SCC OnLine P&H 3760], a decision relied on by the learned counsel for the appellant, a Division Bench of the High Court of Punjab and Haryana was dealing with a case in which the petitioner, who appeared in the JEE (Main) BE/B.Tech examination for the academic year 2021-22, was denied admission in B.Tech Mechanical Engineering programme at the Indian Institute of Technology, Indore, on the ground that, in contravention of clause 15 of the information brochure for the entrance examination, she got herself registered for admission on the strength of an OBC-NCL certificate dated 14.06.2016, instead of an OBC-NCL certificate obtained on or after 01.04.2021, and did not take any steps till the cut-off date of 27.10.2021, for producing a fresh OBC-NCL certificate. Clause 15 of the information brochure, which is extracted in paragraph 10 of the decision of the Division Bench, is pari materia to clause 13 of the information brochure for IISER Aptitude Test (IAT) – 2026. Clause 15 provided that, for seeking admission in the OBC-NCL category, the OBC-NCL certificate should have been issued on or after 01.04.2021 in consonance with the latest guidelines of the Government of India. If any OBC-NCL candidate fails to submit the OBC-NCL certificate (issued on or after 01.04.2021) at the time of online registration, the candidate has to upload a declaration (declaration in lieu of OBC-NCL certificate) to that effect.

In Yoshika Verma [2022 SCC OnLine P&H 3760], the Division Bench noticed that, as per the information brochure, the candidate seeking admission in the OBC-NCL category is required to submit an OBC-NCL certificate issued by the competent authority on or after 01.04.2021. The details in respect of the category, etc., given by the candidates in the registration form cannot be changed in view of the provisions in Rule XIV(30) of the Business Rules notified by the Joint Seat Allocation Authority. The candidates were required to answer queries regarding online verification of documents no later than 31.10.2021, failing which the provisional seat allocation would be cancelled. The candidate whose OBC-NCL certificate is found to be incorrect would be considered as a general category candidate, by changing his/her category, and his/her admission shall be considered in that category.

In Yoshika Verma [2022 SCC OnLine P&H 3760], the Division Bench observed that emphasis on obtaining a fresh OBC-NCL certificate cannot be downplayed. Such a certificate is required to ensure that a person does not belong to the creamy layer. The authorities have to periodically verify this, as the status of a candidate regarding his/her inclusion or exclusion from the creamy layer is subject to change. In such circumstances, the authorities have prescribed and required the candidate to produce an OBC-NCL certificate issued on or after 01.04.2021, which is in sync with the guidelines issued by the Government of India for obtaining an OBC-NCL certificate.

In Yoshika Verma [2022 SCC OnLine P&H 3760], the Division Bench observed that the respondents are required to apply the rules uniformly to all candidates. The respondents have rightly stated in the impugned order rejecting the petitioner's representation dated 20.01.2022 that there were 26 other OBC-NCL candidates whose certificates were not found to be in order and had been denied admission, and in such circumstances, no exception or concession could be made for the petitioner, in ignorance of the claim of the other candidates. The rules and instructions governing admission have to be applied strictly and uniformly to all candidates, and they cannot be diluted by the courts or permitted to be treated as mere technicalities.

In Yoshika Verma [2022 SCC OnLine P&H 3760], the Division Bench observed that the courts or the authorities must ensure that admissions in violation of the rules or instructions governing admission are not ordered or made on the grounds of equity or sympathy. All candidates have to be provided equal treatment and a level playing field by uniformly and strictly implementing the stipulations prescribed by the rules or instructions so as to maintain the sanctity and purity of the admission process and, therefore, those violating the rules or instructions cannot be permitted to obtain admissions on the grounds of misplaced sympathy or equity, thereby rendering the rules otiose or meaningless.

In Yoshika Verma [2022 SCC OnLine P&H 3760], the Division Bench considered the decisions of the Apex Court in Dolly Chhanda [(2005) 9 SCC 779] and Union Public Service Commission v. Gyan Prakash Srivastava [(2012) 1 SCC 537]. From the facts of the aforesaid decisions relied upon by learned counsel for the petitioner as well as that of the case at hand, the Division Bench noticed that the requirements contained in Rule XIV(30) of the Business Rules notified by the Joint Seat Allocation Authority and Rule 15 of the information brochure governing admission to B.Tech course in the Indian Institute of Technology were not present in those cases. Unlike the above cases, the case at hand is not one where the petitioner has been unjustifiably denied admission on the ground of violation of any rule by the respondents or on the basis of any unreasonable technicality, which is clearly evident from the fact that the petitioner, in spite of being aware of the requirement to produce the certificate issued on or after 01.04.2021 at the time of online registration, produced the old certificate, which was issued way back on 14.06.2016 and, therefore, she was at fault and not the respondents. In the above circumstances, the Division Bench dismissed the writ petition. The petitioner challenged the judgment of the Division Bench before the Apex Court in SLP(C)No.11464 of 2022, which ended in dismissal by the order dated 22.07.2022.

We notice that the factual matrix in the case at hand is entirely different from that in the cases dealt with by the Apex Court in Charles K. Skaria [(1980) 2 SCC 752], Dolly Chhanda [(2005) 9 SCC 779] and Ram Kumar Gijroya [(2016) 4 SCC 754]. In the case at hand, as provided in clause 6 of the information brochure for IISER Aptitude Test (IAT) – 2026, to claim reservation in admission as an OBC-NCL candidate, the candidate has to produce the OBC-NCL certificate valid for the financial year 2026-27, and issued on or after 01.04.2026. As per clause 13, such an OBC-NCL certificate should have been issued as per the latest guidelines of the Government of India. In view of the provisions under clauses 6 and 13 of the information brochure, to claim reservation in admission as an OBC candidate, the candidate has to upload the OBC-NCL certificate obtained as per the latest guidelines of the Government of India, issued on or after 01.04.2026, i.e., an OBC-NCL certificate issued during any month of the financial year 2026-27, covering three preceding financial years, viz. 2023-24, 2024-25 and 2025-26. Therefore, the NCL status of an OBC candidate to claim reservation in admission is determined with reference to the income criterion in the previous three financial years preceding the year of admission. If the OBC-NCL certificate uploaded by a candidate along with the application or that uploaded by a candidate (who gave a declaration in lieu of OBC-NCL certificate), before the cut-off date of 21.06.2026, is not valid for the financial year 2026-27, i.e., covering three preceding financial years, such a candidate will be considered for admission only under the unreserved category, in view of the specific provisions contained in clause 13 of the information brochure for IISER Aptitude Test (IAT) – 2026.

In the impugned judgment, the learned Single Judge observed that the initial certificates submitted by both the petitioners revealed that those certificates were stated as valid for a period of one year from the date of issue. Obviously, the validity period mentioned in those certificates covered the date fixed in the information brochure as well as the cut-off date, i.e., 21.06.2026. Subsequently, upon being informed of the stipulation to produce certificates issued on or after 01.04.2026, the petitioners have also submitted such certificates, though beyond the cut-off date. Thus, the petitioners’ claim to be included in the OBC-NCL category remained valid at the time of submitting their applications and during the admission process.

As contended by the learned counsel for the appellant Joint Admission Committee, every candidate seeking reservation in admission as an OBC candidate is required to submit a certificate confirming his/her status as OBC and also NCL status issued by the competent authority. NCL applies to OBC candidates covered under the income/wealth test criterion. The income limit is determined by the income earned in the three previous financial years preceding the year of admission. The validity of NCL issued during any month of a financial year, covering three preceding financial years, would be from April to March of that financial year.

As per clause 6 of the information brochure for IISER Aptitude Test (IAT) - 2026, the OBC-NCL certificate should be valid for the financial year 2026-27, and issued on or after 01.04.2026. As per clause 13, the OBC-NCL certificate should have been issued on or after 01.04.2026, as per the latest guidelines of the Government of India. A reading of the provisions under clauses 6 and 13 of the information brochure would make it explicitly clear that, at the time of submission of the online application, to claim reservation in admission as an OBC candidate, the candidate has to upload the OBC-NCL certificate obtained as per the latest guidelines of the Government of India, issued on or after 01.04.2026, i.e., an OBC-NCL certificate issued during any month of the financial year 2026-27, covering three preceding financial years, viz. 2023-24, 2024-25 and 2025-26. In the instant case, admittedly, Ext.P2 OBC-NCL certificate dated 09.02.2026 uploaded by the petitioner in W.P.(C)No.26238 of 2026 and Ext.P1 OBC-NCL certificate dated 13.01.2026 uploaded by the petitioner in W.P.(C)No.27028 of 2026 were issued during the financial year 2025-26, covering three preceding financial years, viz. 2022-23, 2023-24 and 2024-25, which do not meet the requirements of clauses 6 and 13 of the information brochure, to claim reservation in admission as an OBC candidate.

We notice that, as contended by the learned counsel for the appellant Joint Admission Committee, the petitioner in W.P.(C)No.27028 of 2026, intentionally concealed Ext.R2(b) undertaking given by her on 18.06.2026, in lieu of OBC-NCL certificate, issued on or after 01.04.2026, as per the requirements of clause 13 of the information brochure, who had also undertaken to upload OBC-NCL certificate on or before 21.06.2026, failing which she will not be considered for admission under OBC-NCL category. This clearly shows that the petitioner in that writ petition has approached this Court with unclean hands, suppressing material facts. We also notice that the petitioner in W.P.(C)No.26238 of 2026, who failed to upload OBC-NCL certificate issued on or after 01.04.2026, as per the requirements of clause 13 of the information brochure, has not even chosen to give any such undertaking.

As per clause 13 of the information brochure, if any OBC-NCL candidate fails to submit the OBC-NCL certificate (issued on or after 01.04.2026) at the time of online application, the candidate has to upload a signed declaration form in lieu of the OBC-NCL certificate. The candidate has to upload a certificate issued on or after 01.04.2026, on or before 21.06.2026. Failing which, the candidate will not be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category.

The petitioner in W.P.(C)No. 26238 of 2026 obtained Ext.P5 OBC-NCL certificate dated 08.07.2026 and the petitioner in W.P.(C)No.27028 of 2026 obtained Ext.P5 OBC-NCL certificate dated 22.06.2026, both issued during the financial year 2026-27, covering three preceding financial years, viz. 2023-24, 2024-25 and 2025-26, only after the cut-off date of 21.06.2026. The validity of Ext.P2 OBC-NCL certificate dated 09.02.2026 issued to the petitioner in W.P.(C)No.26238 of 2026 and Ext.P1 OBC-NCL certificate dated 13.01.2026 issued to the petitioner in W.P.(C)No. 27028 of 2026, expired on March 31, 2026, since both certificates were issued during the financial year 2025-26. Therefore, the finding of the learned Single Judge in the impugned judgment that the petitioners’ claim to be included in the OBC-NCL category remained valid at the time of submitting their applications and during the admission process cannot be sustained in law, which is liable to be set aside, and we do so. In view of the provisions under clause 13 of the information brochure, the petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026, who failed to upload OBC-NCL certificates issued on or after 01.04.2026, on or before 21.06.2026, will not be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category.

In W.P.(C)No.26238 of 2026, one of the reliefs sought for by the petitioner is a declaration that Note to clause 6 of Ext.P1 [Ext.R3(a)/R2(a)] information brochure to the extent it insists that OBC-NCL certificate should be issued by the Government of India valid for the financial year 2026-27 and issued on or after 01.04.2026, is illegal and is liable to be struck down. The information brochure for IISER Aptitude Test (IAT) – 2026 was published in March, 2026. As already noticed hereinbefore, in various clauses of the information brochure, the candidates were clearly informed about the terms and conditions applicable to OBC-NCL certificates. The 1^st respondent in W.A.No.1701 of 2026 filed W.P.(C)No.26238 of 2026 before this Court only on 30.07.2026, raising a belated challenge against the Note to clause 6 of the information brochure.

In view of the provisions under clauses 6 and 13 of the information brochure, to claim reservation in admission as an OBC candidate, the candidate has to upload the OBC-NCL certificate obtained as per the latest guidelines of the Government of India, issued on or after 01.04.2026, i.e., an OBC-NCL certificate issued during any month of the financial year 2026-27, covering three preceding financial years, viz. 2023-24, 2024-25 and 2025-26. Therefore, the NCL status of an OBC candidate to claim reservation in admission is determined with reference to the income criterion in the previous three financial years preceding the year of admission. The claim for reservation in admission as an OBC candidate has to be supported by OBC-NCL certificate issued as per the latest guidelines of the Government of India. In such circumstances, the condition stipulated in the Note to clause 6 of the information brochure for IISER Aptitude Test (IAT) - 2026 that OBC-NCL certificate issued to the candidate claiming reservation in admission should be valid for the financial year 2026-27 and issued on or after 01.04.2026, cannot be said to be arbitrary or illegal.

After the publication of the results of IISER Aptitude Test (IAT) – 2026, the online counselling process for admission commenced, and the document marked as Ext.P11 in W.P.(C)No.27028 of 2026 shows the closing ranks in the first round of counselling. The Joint Admission Committee received approximately 1.3 lakh applications. The submission of the learned counsel for the appellants is that in approximately 1000 cases, candidates could not submit a valid OBC-NCL certificate for one reason or another. After scrutinising the documents, the Committee issued offer letters to the successful candidates, who have also acted on them. Reversing the process would create many problems not only for the Committee but also for the successful candidates. The Committee is working against an extremely tight admission schedule. The classes have to start by the first week of October, 2026, to complete the syllabus. Any concession from the court would create chaos in the admission process.

The learned counsel for the 1^st respondent-petitioner in W.A.No.1701 of 2026 contended that the submission of the learned counsel for the appellant that the Joint Admission Committee is working against an extremely tight admission schedule since the classes have to be started by the first week of October, 2026, for the purpose of completing the syllabus, is not a valid ground to deny admission to meritorious candidates, in view of the law laid down by the Apex Court in S. Krishna Sradha [(2020) 17 SCC 465]. The learned counsel has also referred to Article 46 of the Constitution of India.

Article 46 of the Constitution of India provides for the promotion of educational and economic interests of Scheduled Castes, Scheduled Tribes and other weaker sections. Article 46 provides that the State shall promote with special care the educational and economic interests of the weaker sections of the people, and, in particular, of the Scheduled Castes and the Scheduled Tribes, and shall protect them from social injustice and all forms of exploitation.

In S. Krishna Sradha [(2020) 17 SCC 465], a Three-Judge Bench of the Apex Court observed that denial of admission in a medical course to a meritorious candidate, for no fault of his/her and though he/she has approached the court in time and despite the same not granting any just and equitable relief, would be denial of justice. In exceptional and rarest of rare cases and in a case where all the conditions stipulated in paragraph 33.3 in State (UT of Chandigarh) v. Jasmine Kaur [(2014) 10 SCC 521] are satisfied, the Court can grant exceptional relief to the candidate by granting admission even after the cut-off date is over. The condition stipulated in paragraph 33.3 of the decision in Jasmine Kaur [(2014) 10 SCC 521] reads thus;

In the instant case, admittedly, Ext.P2 OBC-NCL certificate dated 09.02.2026 uploaded by the petitioner in W.P.(C) No.26238 of 2026 and Ext.P1 OBC-NCL certificate dated 13.01.2026 uploaded by the petitioner in W.P.(C)No.27028 of 2026 were issued during the financial year 2025-26, covering three preceding financial years, viz. 2022-23, 2023-24 and 2024-25, which do not meet the requirements of clauses 6 and 13 of the information brochure for IISER Aptitude Test (IAT) - 2026, to claim reservation in admission as an OBC candidate, which requires a candidate to claim reservation in admission as an OBC candidate, to upload the OBC-NCL certificate obtained as per the latest guidelines of the Government of India, issued on or after 01.04.2026, i.e., an OBC-NCL certificate issued during any month of the financial year 2026-27, covering three preceding financial years, viz. 2023-24, 2024-25 and 2025-26. The petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026, who failed to upload OBC-NCL certificates issued on or after 01.04.2026, on or before 21.06.2026, will not be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category. Such a stand taken by the appellant Joint Admission Committee does not violate Article 46 of the Constitution of India. Since the non-selection of the petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 for admission under OBC-NCL category is due to their failure to upload OBC-NCL certificates issued on or after 01.04.2026, on or before 21.06.2026, the principles laid down by the Apex Court in S. Krishna Sradha [(2020) 17 SCC 465], for granting admission even after the cut-off date is over, have no application to the factual matrix of the case at hand.

On the question of territorial jurisdiction, in the impugned judgment dated 13.08.2026, the learned Single Judge held that since the petitioners submitted their applications from Kerala, the rejection of their applications was received in Kerala and the documents claiming the benefit of OBC-NCL category were also submitted from Kerala, certainly a fraction of the cause of action has arisen in Kerala, entitling this Court to consider those writ petitions.

The learned counsel for the appellant argued that, as contended in the counter affidavits filed in W.P.(C)Nos.26238 of 2026 and 27028 of 2026, this Court lacks territorial jurisdiction to entertain the writ petitions. On the other hand, the learned counsel for the 1^st respondent in the respective writ appeals contended that the finding of the learned Single Judge in the impugned judgment, on the territorial jurisdiction of this Court to entertain a writ petition under Article 226 of the Constitution of India, is one made after referring to the law on the point, which is perfectly legal.

On the question of territorial jurisdiction of this Court to entertain the writ petitions, we notice that, as borne out from Ext.R3(a)/R2(a) information brochure for IISER Aptitude Test-2026, the Aptitude Test is conducted for admission to 5-year BS-MS (Dual Degree), 4-year BS and B.Tech Degree programmes for the academic year 2026, in the IISERs established by the Government of India at Berhampur, Bhopal, Kolkata, Mohali, Pune, Thiruvananthapuram and Tirupati, which includes 5-year BS-MS (Dual Degree) programme for science offered at IISER, Thiruvananthapuram, in the State of Kerala. We also notice the absence of any specific grounds in both the writ appeals on the question of territorial jurisdiction, though it is stated as ‘point to be urged’ in the synopsis. Therefore, we find no reason to interfere with the finding of the learned Single Judge in the impugned judgment on the question of territorial jurisdiction.

For the reasons stated hereinbefore, we find that the petitioners in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 are not entitled to any of the reliefs sought for in those writ petitions. On account of their failure to upload OBC-NCL certificates issued on or after 01.04.2026, on or before 21.06.2026, as per the requirements of clauses 6 and 13 of the information brochure for IISER Aptitude Test (IAT) – 2026, they are not entitled to be considered for admission under the OBC-NCL category and will be considered for admission only under the unreserved category. Therefore, we find no reason to sustain the findings of the learned Single Judge in the impugned judgment dated 13.08.2026 in W.P.(C)Nos.26238 of 2026 and 27028 of 2026 on the above aspect.

In the result, these writ appeals are allowed by setting aside the judgment dated 13.08.2026 of the learned Single Judge in W.P.(C)Nos.26238 of 2026 and 27028 of 2026; however, without interfering with the finding in the impugned judgment on territorial jurisdiction.

Consequently, the writ petitions, i.e., W.P.(C)Nos.26238 of 2026 and 27028 of 2026, will stand dismissed.