Created by Fuzzy Cloud

Patna High Court

Ruchika RanjanversusThe Bihar State University Service Commission

Decided
Disposal
DISMISSED

Holding

The court held that the petitioner’s failure to submit the Ph.D. (5‑point) certificate before the stipulated cut‑off date rendered her ineligible, and the rejection of her application was valid.

Summary

The petitioner, Ruchika Ranjan, applied for the post of Assistant Professor in Political Science under Advertisement No. 762 of the Bihar State University Service Commission, which required all documents, including the Ph.D. (5‑point) certificate, to be uploaded by 10 December 2020. Although she uploaded most documents before the deadline, the Ph.D. certificate was sent by speed post on 25 December 2020, after the cut‑off date. The Commission rejected her application on the ground of late submission and lack of NET/BET qualification, despite her claim of exemption under UGC Regulations 2009/2016. The petitioner argued that the certificate was posted before the hard‑copy deadline and that her Ph.D. should exempt her from NET/BET. The Court, relying on prior decisions (CWJC Nos. 10670/2024, 17367/2024, 10262/2024), held that the advertisement’s procedural requirements are mandatory and the late submission rendered the petitioner ineligible. Consequently, the writ petition was dismissed.

Issues considered

  • Whether a Ph.D. (5‑point) certificate submitted after the advertised cut‑off date can be accepted for eligibility.
  • Whether the petitioner is exempt from NET/BET requirements under UGC Regulations 2009 and 2016.
  • Whether the rejection of the petitioner’s application is legally valid given the advertisement’s procedural stipulations.
  • Whether the writ petition can be entertained after the selection process has been completed.

Subjects

  • Ph.D. eligibility
  • NET/BET exemption
  • cut‑off date
  • advertisement compliance
  • selection process
  • writ petition
  • higher education recruitment

Judgment

          IN THE HIGH COURT OF JUDICATURE AT PATNA
                   Civil Writ Jurisdiction Case No.6201 of 2025
     ======================================================
     Ruchika Ranjan W/o Raushan Prakash, R/o B-12, Housing Colony, P.O.-
     Lohia Nagar, P.S.-Kankarbagh, District-Patna-800020, at present residing at
     House No.-410, Block-D-16, Sector-7, Rohini, Delhi-100085.

                                                               ... ... Petitioner/s
                                       Versus
1.   The Bihar State University Service Commission through its Secretary, Patna.
2.   The Secretary, The Bihar State University Service Commission, Patna.
3.   The Principal Secretary, Education Department, Government of Bihar,
     Patna.

                                               ... ... Respondent/s
     ======================================================
     Appearance :
     For the Petitioner/s   :      Mr. Madan Prasad Singh No.2, Adv.
                                   Mr. Dharmendra Kumar Raju, Adv.
     For the State          :      Mr. Yogendra Pd. Sinha, AAG 7
                                   Mr. AC to AAG 7
     For the BSUSC          :      Mr. Tuhin Shankar, Adv.

     =======================================================
     CORAM: HONOURABLE MR. JUSTICE HARISH KUMAR
                     ORAL JUDGMENT
     Date : 27-01-2026
                 Heard the parties.

                     2. The petitioner is aggrieved with the information

      No. BSUSC 762 dated 13.03.2025 whereunder the petitioner’s

      application at sl No. 838 has been rejected on the ground of her

      Ph.D. Degree is of the year 2006 and the certificate of (5) five

      point has been submitted after the cut off date as prescribed in

      the advertisement, besides the petitioner has no qualification of

      NET/BET.

                     3. The facts of the case as briefly stated in the writ

      petition are that the petitioner, an aspirant for the post of

      Assistant Professor in Political Science in terms with the
Patna High Court CWJC No.6201 of 2025 dt.27-01-2026
                                           2/5




         Advertisement No. 762 dated 21.09.2020 issued by the Bihar

         State University Service Commission (in short ‘Commission’),

         submitted her application. It is to be noted that the last date for

         submission of application was scheduled till 02.11.2020. The

         Commission further issued communication that the last date for

         receipt of application on Commission’s web portal was extended

         upto 10.12.2020 and for hard copy has been extended upto

         30.12.2020.

                       4. Learned Advocate for the petitioner submitted that

         the very rejection of the candidature of the petitioner is out and

         out unsustainable in law as well as on facts, besides it shows

         non application of mind. Since the petitioner was not required to

         pass NET/BET as she had already passed Ph.D. examination on

         20.11.2006, hence as per the requirement in the advertisement

         which clearly stipulates that those who have been acquired

         Ph.D. Degree in accordance with the UGC Regulation 2009 and

         2016 are exempted from passing NET/BET. It is further

         contended that all the certificates were duly attached with the

         application and the same was uploaded on the web portal of the

         Commission before the cut off date. However, (5) five point

         certificate has been issued belatedly vide letter No. 1071/20

         dated 23.12.2020 by the Magadh University, the same was sent
Patna High Court CWJC No.6201 of 2025 dt.27-01-2026
                                           3/5




         to the Commission on 25.12.2020 under Speed Post, much prior

         to the last date prescribed for submitting hard copy of the

         certificates along with application. In the aforesaid premise, it is

         submitted that the rejection of the candidature of the petitioner

         is out and out arbitrary and illegal.

                       5. Mr. Tuhin Shankar, learned Advocate for the

         Commission submitted that the date for uploading the

         application form and the relevant documents were duly

         prescribed by the Commission and the petitioner was required to

         upload all the documents along with the certificate before the

         cut off date 10.12.2020. However, the petitioner failed to do so

         and subsequent thereto, the petitioner has sent the Ph.D. (5) five

         point certificate through Speed Post which was not at all

         acceptable in terms with the advertisement, especially Clause

         11.1 and Clause 15. It is further submitted that the hard copy of

         only those documents could be filed which have already been

         uploaded in the web portal of the Commission since the

         petitioner has failed to upload the Ph.D. (5) five point certificate

         before the cut off date of 10.12.2020, his candidature has rightly

         been rejected.

                       6. The identical issue has come up for consideration

         before this Court in CWJC No. 10670 of 2024 along with other
Patna High Court CWJC No.6201 of 2025 dt.27-01-2026
                                           4/5




         analogous cases which came to be disposed of by the coordinate

         Bench of this Court on 27.07.2024, wherein the Court has been

         pleased to hold that the selection process must be conducted

         strictly in accordance with the stipulated procedure in the

         advertisement. Moreover, the petitioner’s candidature cannot be

         accepted on the strength of Ph.D. (5) five point criteria,

         certificate signed by the Registrar of the concerned University,

         submitted subsequent to the last date of submission of the

         application       prescribed in the advertisement or the time

         extended for such submission by the Commission. Similar issue

         has also come up for consideration in CWJC No. 17367 of

         2024, wherein the Court has refused to extend the relief after

         having found that the Ph.D. (5) five point certificate has not

         been submitted in terms with the advertisement. Besides the

         aforesaid fact, the Court has also taken note of the fact that the

         selection process has already been           completed   and the

         candidates have been selected and in the event if the writ

         application is allowed, one candidate in the category of the

         petitioner shall be ousted but then the petitioner has not been

         impleaded the last candidate in her category as a respondent

         which further makes the writ application vulnerable. Further in

         CWJC No. 10262 of 2024, this Court has held that the cut off
             Patna High Court CWJC No.6201 of 2025 dt.27-01-2026
                                                        5/5




                      date as prescribed in the advertisement should be scrupulously

                      followed, failing which the candidate is not eligible to get the

                      benefit.

                                    7. Having considered the submissions advanced by

                      the learned Advocates for the respective parties and taking note

                      of the legal position as well as the admitted fact that the

                      petitioner failed to submit her application alongwith Ph.D. (5)

                      five point certificate before the cut off date which was

                      prescribed for uploading all the documents, in terms with the

                      specific stipulation of the captioned advertisement, besides the

                      facts, the entire selection procedure has culminated with the

                      appointment of the successful candidates, this Court does not

                      find any merit in the writ petition. Accordingly, the same stands

                      dismissed.




                                                  (Harish Kumar, J)
Anjani/-
AFR/NAFR
CAV DATE
Uploading Date            30.01.2026
Transmission Date


Continue reading with your account

Sign in to read the full judgment. It’s free.

Sign in to read

Checking your session…

For a signed copy suitable for filing, refer to the court's website.