In a significant ruling, the Supreme Court, on January 19, overturned the decision of the Uttar Pradesh Public Service Commission (UPPSC) to reject the application of Sadaf Imran for the Judicial Service (Junior Division) Examination. The Court directed the UPPSC to declare the results of the petitioner, asserting that the rejection of an application should not impede the declaration of results.
The case revolved around the denial of Sadaf Imran’s candidacy by the UPPSC to participate in the Judicial Service (Junior Division) Main Examination – 2022. Despite clearing the preliminary examination, Imran was barred from the Mains due to a delay in submitting hard copies of the application form, attributed to postal service deficiencies.
Imran argued that her online submission was accepted by the UPPSC, highlighting the delay as a result of postal services. Despite appealing to the UPPSC against the cancellation of her candidature, Imran’s plea was rejected, prompting her to approach the Supreme Court under Article 32 of the Constitution, asserting a violation of her fundamental right to examination access under Article 21.
Notably, on May 22, 2023, the Supreme Court provided interim relief, instructing the UPPSC to provisionally permit Imran to appear in the Mains examination. Following this relief, Imran successfully cleared the Mains and became eligible for the interview stage.
On November 21, 2023, the Court sought the Commission’s sealed cover submission of Imran’s interview results for review. After hearing both parties, the Court reserved its judgment on December 12, 2023.
Backdrop of the Case:
The controversy stemmed from the UPPSC’s refusal to allow Imran to participate in the Mains examination due to a one-day delay in receiving hard copies. Imran, citing postal service delays, emphasized that her online submission had been timely accepted by the Commission. Despite Imran’s appeal to the UPPSC, her candidature was dismissed, leading her to approach the Supreme Court to safeguard her fundamental right to examination access.
Court’s Directive and Impugned Order Set Aside:
The Supreme Court, in its decisive judgment, set aside the UPPSC’s impugned order that rejected Imran’s candidature for the Mains Examination. The Court explicitly directed the UPPSC to declare Imran’s results and transmit them to the State of Uttar Pradesh. This landmark decision reinforces the principle that administrative hindrances should not obstruct the vindication of a candidate’s right to examination.
Article 32 Invoked: Fundamental Rights Safeguarded:
Imran invoked Article 32 of the Constitution, seeking redressal for the violation of her fundamental right under Article 21 – the right to life and personal liberty. The Supreme Court, acknowledging the constitutional significance of the case, intervened to ensure the protection of Imran’s right to fair access to the examination process.
Interim Relief Paves the Way for Success:
The Court’s interim relief on May 22, 2023, played a pivotal role in Imran’s journey to success. By provisionally allowing her to participate in the Mains examination, the Court granted her the opportunity to showcase her capabilities, leading to her successful progression through subsequent stages.
Sealed Cover Submission and Reserved Judgment:
The Court, on November 21, 2023, sought the UPPSC’s sealed cover submission of Imran’s interview results. After considering the submissions of both parties and due deliberation, the Court reserved its judgment on December 12, 2023, signifying the gravity and complexity of the case.
Conclusion: Upholding Justice and Fair Access:
The Supreme Court’s verdict in the case of Sadaf Imran v. UPPSC marks a significant stride in upholding the fundamental rights of candidates in the examination process. By setting aside the impugned order and directing the declaration of results, the Court sends a strong message that administrative lapses should not impede a candidate’s right to pursue their chosen path through fair and just means.
This landmark judgment serves as a precedent, emphasizing the sanctity of the examination process and the need to safeguard the fundamental rights of candidates against arbitrary administrative decisions. The Supreme Court’s commitment to justice and fairness shines through in its unwavering protection of Sadaf Imran’s right to examination access, ensuring that merit and diligence triumph over procedural impediments.