Jitendra Kumar Singh v. State of U.P. (2010)

The Supreme Court clarified how reservation works in public jobs. Fee/age relaxations help a candidate enter the exam, but the selection bar stays the same for everyone. If a reserved category candidate scores above the last general candidate, they can get a general seat on merit.

Women and sports quotas work horizontally. If such seats are not filled, they do not carry forward; they are filled from the same selection on merit. The Court found no proof of favoritism in the recruitment.

• Can a reserved candidate who took fee/age relaxation be counted in the general list if their score is higher?
• Would such inclusion break the 50% cap on reservation?
• Is women’s reservation valid under the Constitution?
• Can unfilled women’s quota or sports quota seats be carried forward?
• Was the recruitment process arbitrary or manipulated?

Holding

• Fee/age relaxations do not dilute selection standards. A reserved candidate who outperforms the last general candidate may be placed in the general list.
• This adjustment does not break the 50% cap because such candidates are counted as general on merit.
• Women’s reservation is valid. It is a horizontal reservation and cannot be carried forward.
• Sports quota is also horizontal; unfilled seats do not carry forward and must be filled on merit from the same selection.
• No reliable evidence of favoritism or manipulation was shown.

Eligibility relaxations ≠ selection relaxations. Merit remains a single ladder for all. Horizontal reservations (women, sports) cut across categories and do not justify carry forward. Articles 16(1) and 16(4) must be read together to protect both equal opportunity and social justice within the 50% cap.

• Keeps the playing field common at the selection stage.
• Protects merit while allowing genuine access support at entry.
• Clarifies handling of horizontal quotas for future recruitments.
• Aligns with Indra Sawhney and the 50% cap discipline.

1. Relaxation for eligibility ≠ relaxation for selection.
2. High-scoring reserved candidates can occupy general seats.
3. Horizontal quotas do not carry forward.
4. 50% cap stands firm; count merit in the general list.
5. No proof of favoritism was established.

Mnemonic: E-M-H-C-N — Eligibility, Merit, Horizontal, Cap, No favoritism.

1. Spot the relaxation: entry only.
2. Check the list: merit → general list possible.
3. Apply horizontal rule: no carry forward; 50% cap safe.

Horizontal Reservation

A quota that cuts across all categories (e.g., women, sports) and is adjusted within each category.

50% Cap

Judicial limit that reservation should not normally exceed half of total seats.

Eligibility Relaxation

Support like fee/age relaxation to enter the exam; it does not lower selection standards.