Authority: Gauhati High Court (High Court of Assam, Nagaland, Mizoram and Arunachal Pradesh)

Order Date: 23.06.2026

Case Overview

  • Appellant: Sameer Ranjan Das, resident of Digboi, Tinsukia, Assam.
  • Respondents: (1) Indian Oil Corporation Ltd.; (2) Deputy General Manager Human Resource, IOCL Guwahati Refinery; (3) District Commissioner/District Magistrate Kamrup (R); (4) Kangkan Jyoti Malakar (the writ petitioner in the earlier case).
  • The dispute arose from the recruitment advertisement dated 20‑Jul‑2024 for the post of Junior Engineering Assistant‑IV (Production) at IOCL, which required a caste certificate in a prescribed format stating the specific caste.
  • Malakar’s application was rejected on 29‑Sep‑2024 because his caste certificate dated 04‑Nov‑2019 did not specify the particular caste, only stating “Scheduled Caste”.
  • Malakar filed WP(C) 62/2025; the Single Judge’s order dated 10‑Dec‑2025 upheld IOCL’s rejection but directed IOCL to consider an older certificate dated 30‑Apr‑2011 that identified him as belonging to the “Mali” community, and to allow him to undergo the selection process.
  • Following that order, IOCL appointed Malakar to the post after he scored higher marks than the appellant.
  • The appellant filed I.A(C) No.549/2026 for leave to appeal the Single Judge’s order, which was allowed on 23‑Feb‑2026, leading to the present appeal.
  • The court examined the prescribed format of the caste certificate (Paragraph‑A) and found that it explicitly requires the specific caste to be entered and related to one of the listed Scheduled Castes/Tribes Orders.
  • The court noted that Malakar’s 04‑Nov‑2019 certificate did not mention any specific caste, and the 30‑Apr‑2011 certificate was not part of the application and did not conform to the advertised format.
  • Citing precedents (Mohit Kumar 2025 INSC 704, Hemkanta Lalung 2025, Bedanga Talukdar 2011 SSC 84, Dolly Chhanda 2005 SCC 779), the court held that recruitment advertisements bind both applicants and the recruiting authority, and no relaxation is permissible without a reserved power.
  • The court concluded that the Single Judge erred in directing IOCL to rely on the 30‑Apr‑2011 certificate and that the appellant should not be penalised for the Deputy Commissioner’s omission, but the responsibility to verify the certificate lies with the candidate.

Final Outcome

  • The directions in Paragraph 14 of the order dated 10‑Dec‑2025 are set aside as unsustainable in law.
  • Any actions taken by IOCL pursuant to those directions, including the appointment of Kangkan Jyoti Malakar, are also set aside.
  • The post of Junior Engineering Assistant‑IV (Production) shall be filled by the next candidate who secured the highest marks after the appellant.
  • The appeal is allowed.

Topics: Recruitment, Caste Certificate, Judicial Ruling