Uttar Pradesh Industrial Training Institutes (Instructors) Service Rules, 2014 – Recruitment – Candidate participating in selection process – Whether estopped from challenging selection process after participation? – Held, Ordinarily Yes; however, not where the selection process itself is arbitrary or contrary to the statutory rules. The appellants, possessing Craft Instructor Training Scheme (CITS) certificates, applied pursuant to recruitment advertisements issued in 2014 and 2015 for appointment as Instructors in Industrial Training Institutes. They participated in the selection process without challenging the recruitment rules or the advertisements. Their candidature was rejected as they failed to secure the qualifying/cut-off marks fixed by the Selection Committee. The appellants challenged the selection contending that the Selection Committee had illegally prescribed qualifying/cut-off marks though the 2014 Rules did not authorise fixation of such cut-off marks, resulting in a large number of vacancies remaining unfilled. Whether candidates, having participated in the selection process without protest, are precluded from challenging the selection? – Held, Ordinarily Yes; however, not where the selection process is vitiated by arbitrariness or illegality. The Supreme Court held that although a candidate who knowingly participates in a selection process ordinarily cannot subsequently challenge it, such principle does not apply where the selection process itself suffers from arbitrariness or violates the statutory recruitment rules. The 2014 Rules permitted shortlisting only where applications were received in large numbers by restricting interview candidates to four times the vacancies. They did not authorise fixation of qualifying or cut-off marks for excluding otherwise eligible candidates. Since the Selection Committee introduced an unauthorised cut-off, excluded eligible candidates despite vacancies remaining unfilled, and thereby altered the prescribed procedure, the entire process stood vitiated by arbitrariness. The appellants were therefore entitled to appropriate relief notwithstanding their participation in the recruitment process. Ratio Decidendi A candidate who participates in a recruitment process without objection is ordinarily estopped from challenging the selection process after being unsuccessful. However, such estoppel does not apply where the selection authority acts arbitrarily or contrary to the statutory recruitment rules. Any procedure introduced by the Selection Committee beyond the recruitment rules, resulting in exclusion of otherwise eligible candidates, is illegal and liable to be set aside notwithstanding the candidates' participation in the selection process. 2026 INSC 741

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Uttar Pradesh Industrial Training Institutes (Instructors) Service Rules, 2014 – Recruitment – Candidate participating in selection process – Whether estopped from challenging selection process after participation? – Held, Ordinarily Yes; however, not where the selection process itself is arbitrary or contrary to the statutory rules.

The appellants, possessing Craft Instructor Training Scheme (CITS) certificates, applied pursuant to recruitment advertisements issued in 2014 and 2015 for appointment as Instructors in Industrial Training Institutes. They participated in the selection process without challenging the recruitment rules or the advertisements. Their candidature was rejected as they failed to secure the qualifying/cut-off marks fixed by the Selection Committee. The appellants challenged the selection contending that the Selection Committee had illegally prescribed qualifying/cut-off marks though the 2014 Rules did not authorise fixation of such cut-off marks, resulting in a large number of vacancies remaining unfilled. Whether candidates, having participated in the selection process without protest, are precluded from challenging the selection? – Held, Ordinarily Yes; however, not where the selection process is vitiated by arbitrariness or illegality.

The Supreme Court held that although a candidate who knowingly participates in a selection process ordinarily cannot subsequently challenge it, such principle does not apply where the selection process itself suffers from arbitrariness or violates the statutory recruitment rules. The 2014 Rules permitted shortlisting only where applications were received in large numbers by restricting interview candidates to four times the vacancies. They did not authorise fixation of qualifying or cut-off marks for excluding otherwise eligible candidates. Since the Selection Committee introduced an unauthorised cut-off, excluded eligible candidates despite vacancies remaining unfilled, and thereby altered the prescribed procedure, the entire process stood vitiated by arbitrariness. The appellants were therefore entitled to appropriate relief notwithstanding their participation in the recruitment process.

Ratio Decidendi

A candidate who participates in a recruitment process without objection is ordinarily estopped from challenging the selection process after being unsuccessful. However, such estoppel does not apply where the selection authority acts arbitrarily or contrary to the statutory recruitment rules. Any procedure introduced by the Selection Committee beyond the recruitment rules, resulting in exclusion of otherwise eligible candidates, is illegal and liable to be set aside notwithstanding the candidates' participation in the selection process. 2026 INSC 741