Delhi HC petition for constable selection in CAPF/SSF

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Chauhan Anil Bhola vs Union Of India & Ors on 23 March, 2026

Author: V. Kameswar Rao

Bench: V. Kameswar Rao, Manmeet Pritam Singh Arora

$~84
* IN THE HIGH COURT OF DELHI AT NEW DELHI
% Date of Decision : 23.03.2026

                      +       W.P.(C) 3706/2026
                              CHAUHAN ANIL BHOLA                                       .....Petitioner
                                          Through:             Mr. Saroj Kumar Singh and Mr.
                                                               Saurabh Nath, Advocates

                                                 versus

                              UNION OF INDIA & ORS.                                 .....Respondents
                                            Through:           Mr. Neeraj, SPC with Mr. Sanjay Pal,
                                                               Mr. Ajay Pal(CRPF), Mr. Soumyadip
                                                               Chakraborty, Advocates for Union of
                                                               India
                      CORAM:
                      HON'BLE MR. JUSTICE V. KAMESWAR RAO
                      HON'BLE MS. JUSTICE MANMEET PRITAM SINGH ARORA

                      V. KAMESWAR RAO, J. (ORAL) 1.      This petition has been filed with the following prayers: -

"a) give direction to the respondent to select the candidature of
the petitioner as early as possible

b) Any other order or relief which Hon'ble court may deem fit
and proper under the facts and circumstances of the case in the
interest of justice."
2. The petitioner is a resident of Mumbai and had applied for the post of
constable/GD in the Central Armed Police Force ('CAPF'), SSF, and
Rifleman in Assam Rifles Examination, 2024.

1.  It is a conceded position that his candidature was rejected. It is only
                     through his counsel that he got issued a legal notice dated 27.11.2024. The
                     same was replied to on 11.09.2025 by the CISF Unit RCFL Mumbai.
   

2.  In response to a query raised by this Court on delay in approaching
                     this Court, as well as the reason for not invoking the jurisdiction of the
                     competent court in Maharashtra, learned counsel for the petitioner has given
                     twofold explanation. Firstly, it is submitted that the petitioner received
                     response to the legal notice only on 11.09.2025. Secondly, that the initial
                     notification was issued by the Staff Selection Commission, Lodhi Road,
                     New Delhi, as such part of cause of action has arisen within the territorial
                     jurisdiction of this Court.
   

3.  Mr. Neeraj, Advocate, who appears for the respondents, informs the
                     Court that the challenge in the present petition is to an examination of 2024.
                     Even thereafter, a further notification of 2025 has been issued and the
                     process has been concluded. In other words, it is contended that it is too late
                     for the petitioner to approach this Court challenging his rejection pursuant to
                     the notification for the 2024 examination.
   

4.  We agree with the said submission of the learned counsel for the
                     respondents. This we say so because the cause of action, is the rejection of
                     his candidature, which is coincedingly from Mumbai, Maharashtra, and even
                     the reply to the notice was issued by the CISF Unit at Mumbai. It follows
                     the issuance of the notification, which was pan-India, will not give a cause
                     of action to the petitioner to approach this Court. Even otherwise this Court
                     is not forum convenience to entertain this petition. In any case, the
   
                      respondents, while answering the legal notice issued on behalf of by the
                     petitioner vide letter dated 11.09.2025, have stated as under: -
   

"2. In this regard, it is to inform that Shri Chauhan Anil Bhola
(hereinafter referred to as me petitioner) had applied for
Constable/GD in Central Armed Police Force (CAPFs), SSF, and
Rifleman (GD) in Assam Rifles Examination 2024. He was issued
Admit Card for Roll No. 7204010512 from CRPF Directorate, New
Delhi (Nodal Agency) for attending PST/PET & DV/DME on
07.10.2024 at the Recruitment Center, CISF Unit RCFL Mumbai,
Maharashtra (400074).

1. Accordingly, he appeared for PST/PET and DV/DME on
   07.10.2024 at Recruitment Centre CISF Unit RCFL Mumbai. The
   petitioner qualified in PST/PET examination. Thereafter, during
   Document Verification (DV), the petitioner produced OBC Caste
   Certificate dated 14.12.2023 issued from Tehsildar Kasimabad,
   Ghazipur, Uttar Pradesh and as per his domicile certificate dated
   06.03.2019, he is the resident of Jan Kalyan Samaj Seva Society,
   Islam Compound, Ghandi Nagar, Near Durga Mata Mandir,
   Kandivali (West) Mumbai, Maharashtra.

2. In this regard, it is pertinent to mention here that in accordance
   with laid down guidelines/instructions issued by SSC vide their
   notification dated 24.11.2023 vide Para 6 (6.2) and Para 20 (5) it
   clearly mentioned that "A candidate belonging to a caste of SC, ST or OBC
   category, on migration from one State to another State will have to make an
   informed choice whether to get the benefit of reservation in the State of origin or
   to appear as unreserved candidate from the State of Migration. Such choice will
   have to be exercised by the candidate in the online Application Form. No request
   for change of such option, after the submission of Application Form, will be
   entertained by the Commission. In case, a candidate opt to avail the benefit of
   reservation from the State of origin, he will have to submit information about the
   District and State of current domicile as well as the District and State of his
   origin in the Application Form. His candidature in such cases will be considered
   from the State of origin."

3. Verification Board checked the online form of the petitioner, it
   was found that the petitioner had marked "NO" in column No. 21.1 of
   the online form in response to the question regarding "Have you

                         migrated from the State/UT of your origin to another State/UT?"
   

Whereas, he should have mentioned 'Yes' in that column as he is
migrated from another State/UT in the Maharashtra.
06. The petitioner was claiming OBC reservation from Maharashtra,
then he should typically need to produce a valid OBC certificate
issued by the Maharashtra state, which he has not produced, whereas
in terms of Directorate General, C.R.P.F. (Recruitment Branch) East
Block-07, Level-04, Sector-01, R.K. Puram, New Delhi-110066
(Ministry of Home Affairs) vide letter No.A.VI-1/2024-Rectt(SSB)-
CT/GD-2024 Dated 12.09.2024 had given the following
instructions/guidelines during the checking of Domicile and caste
certificate:-

"7.3.4. Domicile Certificate:

 As per the Notice of Examination, candidates have to
produce Domicile Certificate for the District and State/ UT
filled by them in their online application form
 No change of Domicile District and State/UT shall be
considered at the stage of DV. If there is any variation
between District and State/UT in the online application and
Domicile Certificate, candidature of such candidates will be
REJECTED.

 The reserve category candidates who have migrated from
the State/ UT of their origin to another State/UT can take the
benefit of reservation against the vacancies of the State UT of
their origin.

 If such candidates want to be considered against
vacancies of the migrated State/UT then they will be
considered only against the unreserved vacancies of the
migrated State UT
 Above option has already been exercised by the
candidates in their online application form
 The reserve category candidates who have migrated from
the State/UT of their origin to another State/UT and have
chosen to avail benefit of reservation from the State UIT of
origin, they have to produce:

 Caste/Category certificate from Origin State.
 Domicile Certificate of the migrated State/UT,"
8. Taking into consideration the case of the petitioner, DV/DME
Board had given 07 days' extra time to submit the required OBC
Caste Certificate in the prescribed format issued from his domicile
state (Maharashtra), based on his declaration in the online form. The
recruitment board had followed the CRPF Directorate
instruction/guidelines dated letter No.A.VI-1/2024-Rectt(SSB)-
CT/GD-2024 Dated 12.09.2024 (para 6.5.8) and considering the
principles of natural justice, a letter (Annexure-"C") was issued to
him with direction to produce the Caste certificate in prescribed
formate by 14.10.2024 at 10 AM and also informed him that if he will
fail to submit required document, his candidature will be finally
rejected. The petitioner acknowledged this letter on the same date and
time.

1. But, the petitioner failed to produce the OBC Caste certificate in
   prescribed format issued from domicile state i.e. Maharashtra within
   stipulated time i.e. on or before 14.10.2024, and hence, his
   candidature was rejected as per the prescribed guidelines."

2.  In view of the above position, we are of the view that there is no merit
                     in the challenge made by the petitioner in this petition. Accordingly, the
                     petition is dismissed along with pending applications.
   

V. KAMESWAR RAO, J

                                                        MANMEET PRITAM SINGH ARORA, J
                      MARCH 23, 2026/rhc