Raj HC dismisses challenge to LDC recruitment process, says PwBD candidate far below cut-off cannot question selection methodology

Jaipur/Jodhpur: The Rajasthan High Court has dismissed a writ petition challenging the recruitment process for Junior Judicial Assistant / Clerk Grade-II posts, holding that a candidate whose marks are far below the cut-off cannot seek to reopen a concluded recruitment process by raising academic objections regarding implementation of reservation.

The Division Bench of Justice Dr. Pushpendra Singh Bhati and Justice Sandeep Shah passed the order in D.B. Civil Writ Petition No. 20805/2024, Anmol Lohia vs Rajasthan High Court & Ors., decided on March 6, 2026.

The Court observed that once it becomes evident that the petitioner’s marks fall substantially below the zone of consideration, any elaborate challenge to the methodology of reservation or shortlisting becomes merely theoretical and incapable of affecting the petitioner’s position in the merit list.

The case arose from a joint recruitment advertisement issued on August 5, 2022 for the posts of Junior Judicial Assistant in the Rajasthan High Court, Clerk Grade-II in the Rajasthan State Judicial Academy, and clerical posts in District Courts and Legal Services Authorities. The advertisement also provided horizontal reservation for Persons with Benchmark Disabilities (PwBD) in accordance with the Rights of Persons with Disabilities Act, 2016.

The petitioner, claiming to suffer from 70% permanent disability under the category of “Blindness and Low Vision”, applied under the PwBD category and appeared in the written examination conducted on March 12, 2023. He was also granted compensatory time in the examination on account of his disability.

After evaluation, the petitioner secured 138.9152 raw marks and 139.2503 normalized marks in the written examination. However, he was not shortlisted for the next stage of the recruitment process, namely the Computer Test (Speed and Efficiency Test), as his marks were below the range of candidates shortlisted category-wise.

The petitioner challenged the recruitment process on the ground that the provisions of Section 34 of the Rights of Persons with Disabilities Act, 2016 had not been properly implemented. It was argued that although 22 posts were earmarked for candidates belonging to the Blind and Low Vision category, only six candidates were ultimately selected, leaving several posts unfilled.

It was further contended that no separate cut-off for the Blind and Low Vision category had been declared at the stage of shortlisting for the Computer Test, which according to the petitioner defeated the object of horizontal reservation under the 2016 Act.

Opposing the petition, counsel for the Rajasthan High Court submitted that the recruitment process had been conducted strictly in accordance with the advertisement and applicable rules. It was argued that reservation for PwBD candidates is horizontal in nature and operates across vertical categories, and therefore does not require declaration of a separate cut-off at the stage of the written examination.

Reliance was placed on the Division Bench judgment of the Rajasthan High Court in Rohitash Kumar Jat vs Rajasthan High Court (2023), which had held that horizontal reservation does not require preparation of a separate merit list or declaration of separate cut-off marks for PwBD candidates at the written exam stage.

The respondents also relied on the Supreme Court judgment in Rekha Sharma vs Rajasthan High Court (2024) to argue that candidates who have consciously participated in a recruitment process cannot challenge its methodology after being declared unsuccessful.

After examining the record, the Court noted that the petitioner’s marks were far below the relevant cut-off. The General category cut-off for the written examination was 196.3451 marks, placing the petitioner well outside the zone of consideration.

The Bench further observed that the petitioner had not demonstrated that any candidate belonging to the Blind and Low Vision category with lower marks than him had been shortlisted or selected. In the absence of such prejudice, the grievance raised by the petitioner remained speculative.

The Court held that even if the petitioner were to be granted every possible benefit claimed by him, including hypothetical adjustments under horizontal reservation, his score remained far below the threshold required to enter the zone of consideration.

The Court also took note of the fact that the recruitment process had already concluded in June 2023 and appointments had been made. Interference at such a belated stage, the Court observed, would unsettle administrative certainty and affect the rights of candidates who were not parties before the Court.

Holding that the controversy was already settled by precedent and that no demonstrable illegality had been established, the Court dismissed the writ petition.

Case Title
Anmol Lohia vs Rajasthan High Court & Ors.

Case Number
D.B. Civil Writ Petition No. 20805/2024

Court
High Court of Judicature for Rajasthan, Bench at Jodhpur

Bench
Hon’ble Dr. Justice Pushpendra Singh Bhati
Hon’ble Mr. Justice Sandeep Shah

Date of Order
06 March 2026

Advocates
For the Petitioner:
Mr. Nishit Shah
Mr. Shreyansh Rathi

For the Respondents:
Ms. Abhilasha Kumbhat

Judgments Relied Upon
Rohitash Kumar Jat vs Rajasthan High Court, Jodhpur (DB Civil Writ Petition No. 9645/2023)
Rekha Sharma vs Rajasthan High Court (Civil Appeal No. 5051 of 2023)