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2026 DAILYLAW 28272 (CHH)

Suman Kumari, W/o Arun Kumar Thakur v. State Of Chhattisgarh Through The Secretary, Department Of Education

2026-01-27

Amitendra Kishore Prasad

body2026
ORDER : Amitendra Kishore Prasad, J. 1. By way of this petition, the petitioner has prayed for following reliefs:- “10.1 That, the Hon'ble Court may kindly be pleased to call for the entire record relating to his case. 10.2 That, the Hon'ble Court may kindly be pleased to allow the writ petition and set-aside the impugned order dated 21.04.2023 (Annexure P/1), in the interest of justice. 10.3 Any other relief/relief's which may deem fit and proper in the facts and circumstances of the case may also be allowed.” 2. Learned counsel for the petitioner submits that the petitioner was born in Village Sanwra, Tahsil Rasda, District Ballia (U.P.) and belongs to Nai (Hajjam) community, which falls under the Other Backward Class category. He further submits that the petitioner solemnized her marriage with Arun Kumar Thakur, who also belongs to the Nai (Hajjam) community, and thereafter joined her matrimonial home at Durg, State of Chhattisgarh. The matrimonial family of the petitioner also belongs to OBC category. Consequent thereto, the petitioner obtained her domicile certificate of Chhattisgarh dated 04.08.2004. It is submitted that the petitioner pursued her higher education after marriage and successfully completed her B.Ed. degree on 25.06.2005 and thereafter obtained M.A. degree in the year 2009. 3. Learned counsel submits that since the petitioner’s caste Nai (Hajjam) is also recognized as OBC in the State of Chhattisgarh, she approached the competent authority for issuance of caste certificate. After due verification, the Sub-Divisional Magistrate issued a caste certificate dated 28.12.2005 certifying her as OBC in Chhattisgarh. It is further submitted that in the year 2019, Chhattisgarh Vyapam issued an advertisement for appointment on the post of Teacher (E-Cadre), pursuant to which the petitioner applied and was duly selected for the subject Biology. He further submits that after more than one year of service, the petitioner was issued a show cause notice dated 24.01.2023 by the office of Joint Director, Education Division, Durg, alleging that she had obtained appointment on the basis of an incorrect caste certificate and calling upon her to submit an explanation. Thereafter, another notice dated 27.01.2023 proposing termination of service was issued. Thereafter, another notice dated 27.01.2023 proposing termination of service was issued. It is contended that the petitioner belongs to Nai (Hajjam) community by birth and marriage, which is notified as OBC in both the States of Uttar Pradesh as well as Chhattisgarh, and therefore, her entitlement to OBC status does not cease merely on account of marriage or migration from one State to another. The petitioner has not misrepresented or suppressed any fact and has relied upon a valid caste certificate issued by the competent authority of the State of Chhattisgarh. 4. Learned counsel submits that it is settled law that where a caste is recognized as OBC in both the States, denial of reservation benefit solely on the ground of inter-State migration is illegal and arbitrary. The petitioner’s caste finds place in the Central List of OBC for Chhattisgarh at Entry No. 26(14). It is further submitted that earlier the petitioner had approached this Court by filing Writ Petition (S) No. 1113/2023, which remained pending and during which the State repeatedly sought time to file its reply but failed to do so. Despite having knowledge of the pendency of the said writ petition, the respondent authorities proceeded to terminate the services of the petitioner, which is ex facie illegal, arbitrary and in violation of principles of natural justice. Accordingly, learned counsel for the petitioner submits that the impugned action of the respondents deserves to be quashed and appropriate relief be granted in favour of the petitioner. 5. On the other hand, learned State counsel opposes the submissions of learned counsel for the petitioner and submits that the instant writ petition is devoid of merits, as the petitioner has failed to raise any cogent or legally sustainable ground in support of her claim. She further submits that it is a well-settled position of law that the benefit of a social status/caste certificate is State- specific. Each State constitutes a distinct unit for the purpose of grant of reservation benefits, and a person who is a permanent resident of one State cannot claim reservation benefits in another State merely on the basis of migration. She further submits that it is a well-settled position of law that the benefit of a social status/caste certificate is State- specific. Each State constitutes a distinct unit for the purpose of grant of reservation benefits, and a person who is a permanent resident of one State cannot claim reservation benefits in another State merely on the basis of migration. Even if a caste bearing the same nomenclature is recognized as Other Backward Class in more than one State, a person migrating from one State to another is not entitled to claim reservation benefits in the migrated State unless a valid caste certificate is issued by the competent authority of that State in accordance with law. 6. In support of the said contention, learned State counsel places reliance upon the judgment of the Hon’ble Supreme Court in Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra & Anr. vs. Union of India & Anr., (1994) 5 SCC 244 , wherein it has been categorically held that the specification of a caste or tribe is always in relation to a particular State or Union Territory, and the benefit attached thereto cannot be automatically extended beyond the territorial limits of that State. 7. Learned State counsel further submits that the advertisement in question specifically mandates, under Clause 8(A), that the candidate must possess and submit a permanent caste certificate issued by the competent authority of the State of Chhattisgarh. The petitioner has failed to produce a valid caste certificate issued by the competent authority, namely the Sub-Divisional Officer of the State of Chhattisgarh, in accordance with the provisions of the Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013. It is further submitted that the caste certificate relied upon by the petitioner was issued for the purpose of employment under the Government of India, and the said certificate itself clearly specifies that it is valid only for posts advertised by the Central Government. Therefore, the petitioner could not have claimed appointment against a post under the State of Chhattisgarh on the basis of such certificate. 8. Learned State counsel submits that in absence of a valid and legally recognized caste certificate issued by the competent authority of the State of Chhattisgarh, the petitioner was not entitled to appointment under the reserved category. Therefore, the petitioner could not have claimed appointment against a post under the State of Chhattisgarh on the basis of such certificate. 8. Learned State counsel submits that in absence of a valid and legally recognized caste certificate issued by the competent authority of the State of Chhattisgarh, the petitioner was not entitled to appointment under the reserved category. Consequently, the action taken by the respondent authorities is strictly in accordance with law and does not warrant any interference by this Court. Accordingly, prays for dismissal of the writ petition. 9. I have heard learned counsel for the parties and perused the documents annexed with the writ petition. 10. The core issue involved in the present writ petition pertains to the entitlement of the petitioner to claim the benefit of reservation in the State of Chhattisgarh on the basis of her caste, which she claims to be recognised as Other Backward Class in both the States of Uttar Pradesh and Chhattisgarh. The law governing the issue is no longer res integra. It is a settled proposition that the benefit of reservation and the social status certificate is State- specific and cannot be availed beyond the territorial limits of the State for which such caste is notified. 11. In Bir Singh v. Delhi Jal Board and others , (2018) 10 SCC 312 the Hon’ble Supreme Court while dealing with the similar issue, has held as under :- “27. A Constitution Bench of this Court in Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] had the occasion to consider the question as to whether a member of the Gouda community which is recognised as “Scheduled Tribe” in the Constitution (Scheduled Tribes) Order, 1950 for the State of Andhra Pradesh would be entitled to admission in a medical institution situated in the State of Maharashtra. This Court noticed the fact that the father of the petitioner in Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] was an employee in Fertiliser Corporation of India, a public sector undertaking and thereafter in Rashtriya Chemicals and Fertilisers Limited, a Government of India undertaking. He belonged to the Gouda community, a recognised Scheduled Tribe of Andhra Pradesh. On his appointment he was stationed at Bombay. He belonged to the Gouda community, a recognised Scheduled Tribe of Andhra Pradesh. On his appointment he was stationed at Bombay. The petitioner came to Bombay at the age of nine years. He completed his studies in Bombay; he submitted an application for his admission in the medical institutions run by Bombay Municipal Corporation which was denied. This denial of admission was based on the Government of India circular dated 22-2-1985, according to which a person who migrates from one State to another is entitled to the benefit of being Scheduled Castes/Scheduled Tribes in the State of origin and not in the State to which he or she migrates. The appellant was held not entitled to be admitted to the Medical College on the basis that he belonged to a Scheduled Tribe in his original State i.e. Andhra Pradesh. 28. After referring to various provisions of the Constitution of India, the background in which the Presidential Orders were issued and several earlier judgments of this Court, it was held as under: (Marri Chandra case [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] , SCC pp. 138-39, para 9) “9. It appears that Scheduled Castes and Scheduled Tribes in some States had to suffer the social disadvantages and did not have the facilities for development and growth. It is, therefore, necessary in order to make them equal in those areas where they have so suffered and are in the state of underdevelopment to have reservations or protection in their favour so that they can compete on equal terms with the more advantageous or developed sections of the community. Extreme social and economic backwardness arising out of traditional practices of untouchability is normally considered as criterion for including a community in the list of Scheduled Castes and Scheduled Tribes. The social conditions of a caste, however, varies from State to State and it will not be proper to generalise any caste or any tribe as a Scheduled Tribe or Scheduled Caste for the whole country. This, however, is a different problem whether a member or the Scheduled Caste in one part of the country who migrates to another State or any other Union territory should continue to be treated as a Scheduled Caste or Scheduled Tribe in which he has migrated. This, however, is a different problem whether a member or the Scheduled Caste in one part of the country who migrates to another State or any other Union territory should continue to be treated as a Scheduled Caste or Scheduled Tribe in which he has migrated. That question has to be judged taking into consideration the interest and well-being of the Scheduled Castes and Scheduled Tribes in the country as a whole.” (emphasis supplied) 29. In Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] , rejecting the contention that (SCC p. 143, para 13) a member of Scheduled Castes/Scheduled Tribes should get the benefit of the status ‘for the purpose of the Constitution throughout the territory of India’, it was observed that if such contention is to be accepted the expression “In relation of that State” would become nugatory. 30. Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] was followed by another Constitution Bench of this Court in Action Committee [Action Committee on Issue of Caste Certificate to SCs/STs in State of Maharashtra v. Union of India, (1994) 5 SCC 244 ] . After referring to Articles 14, 15(1), 15(4), 16(4) and 19 and Part XVI of the Constitution of India and the decisions governing the field and also Articles 341 and 342, it was held as under: (Marri Chandra case [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] , SCC pp. 247 & 259, paras 3 & 16) “3. On a plain reading of clause (1) of Articles 341 and 342 it is manifest that the power of the President is limited to specifying the castes or tribes which shall, for the purposes of the Constitution, be deemed to be Scheduled Castes or Scheduled Tribes in relation to a State or a Union Territory, as the case may be. Once a notification is issued under clause (1) of Articles 341 and 342 of the Constitution, Parliament can by law include in or exclude from the list of Scheduled Castes or Scheduled Tribes, specified in the notification, any caste or tribe but save for that limited purpose the notification issued under clause (1), shall not be varied by any subsequent notification. What is important to notice is that the castes or tribes have to be specified in relation to a given State or Union Territory. That means a given caste or tribe can be a Scheduled Caste or a Scheduled Tribe in relation to the State or Union Territory for which it is specified. These are the relevant provisions with which we shall be concerned while dealing with the grievance made in this petition. *** 16. We may add that considerations for specifying a particular caste or tribe or class for inclusion in the list of Scheduled Castes/Schedule Tribes or Backward Classes in a given State would depend on the nature and extent of disadvantages and social hardships suffered by that caste, tribe or class in that State which may be totally non est in another State to which persons belonging thereto may migrate. Coincidentally it may be that a caste or tribe bearing the same nomenclature is specified in two States but the considerations on the basis of which they have been specified may be totally different. So also the degree of disadvantages of various elements which constitute the input for specification may also be totally different. Therefore, merely because a given caste is specified in State A as a Scheduled Caste does not necessarily mean that if there be another caste bearing the same nomenclature in another State the person belonging to the former would be entitled to the rights, privileges and benefits admissible to a member of the Scheduled Caste of the latter State “for the purposes of this Constitution”. This is an aspect which has to be kept in mind and which was very much in the minds of the Constitution-makers as is evident from the choice of language of Articles 341 and 342 of the Constitution.” (emphasis supplied) * * * 32. In Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] , the Constitution Bench observed that the expression “in relation to that State” must be read meaningfully and harmoniously. It was observed that if a member of Scheduled Castes/Scheduled Tribes gets the benefit of that status throughout the territory of India, the expression “in relation to that State” would become nugatory. It was observed that if a member of Scheduled Castes/Scheduled Tribes gets the benefit of that status throughout the territory of India, the expression “in relation to that State” would become nugatory. If the special privileges or the rights granted to Scheduled Castes or Scheduled Tribes in a particular State are to be made available in all the States and if such benefits are to be carried from State ‘A’ to State ‘B’ on migration, the mandate of Articles 341/342 would get compromised. Such a consequence must be avoided for it is a fundamental rule of interpretation, be it of a statutory enactment or of the Constitution, that wherever and whenever there is a conflict between two provisions, the same should be so interpreted as to give effect to both. “… Nothing is surplus in a Constitution and no part should be made nugatory…”. [Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] ] 33. The issue has to be viewed from another perspective. If a member of a Scheduled Caste/Scheduled Tribe of Andhra Pradesh who had migrated to Maharashtra is to be given the benefit of reservation it will amount to depriving a member of a Scheduled Caste/Scheduled Tribe of Maharashtra by reducing the reservation earmarked for them. It is in this context, in Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 : 1 SCEC 382] , that the Constitution Bench observed as under: (SCC pp. 144, para 14) “14. … But having regard to the purpose, it appears to us that harmonious construction enjoins that we should give to each expression — “in relation to that State” or “for the purposes of this Constitution” — its full meaning and give their full effect. This must be so construed that one must not negate the other. The construction that reservation made in respect of the Scheduled Caste or Tribe of that State is so determined to be entitled to all the privileges and rights under the Constitution in that State would be the most correct way of reading, consistent with the language, purpose and scheme of the Constitution. The construction that reservation made in respect of the Scheduled Caste or Tribe of that State is so determined to be entitled to all the privileges and rights under the Constitution in that State would be the most correct way of reading, consistent with the language, purpose and scheme of the Constitution. Otherwise, one has to bear in mind that if reservations to those who are treated as Scheduled Caste or Tribe in Andhra Pradesh are also given to a boy or a girl who migrates and gets deducted (sic inducted) in the State of Maharashtra or other States where that caste or tribe is not treated as Scheduled Caste or Scheduled Tribe then either reservation will have the effect of depriving the percentage to the member of that caste or tribe in Maharashtra who would be entitled to protection or it would denude the other non-Scheduled Castes or non-Scheduled Tribes in Maharashtra to the proportion that they are entitled to. This cannot be logical or correct result designed by the Constitution.” 34. Unhesitatingly, therefore, it can be said that a person belonging to a Scheduled Caste in one State cannot be deemed to be a Scheduled Caste person in relation to any other State to which he migrates for the purpose of employment or education. The expressions “in relation to that State or Union Territory” and “for the purpose of this Constitution” used in Articles 341 and 342 of the Constitution of India would mean that the benefits of reservation provided for by the Constitution would stand confined to the geographical territories of a State/Union Territory in respect of which the lists of Scheduled Castes/Scheduled Tribes have been notified by the Presidential Orders issued from time to time. A person notified as a Scheduled Caste in State ‘A’ cannot claim the same status in another State on the basis that he is declared as a Scheduled Caste in State ‘A’. * 156. Insofar as the States are, I agree with the majority view that a person who is recognised as a member of Scheduled Castes/Scheduled Tribes in his original State, will be entitled to all the benefits of reservation under the Constitution in that State only and not in other States/Union Territories and not entitled to the benefits of reservation in the migrated State/Union Territory.” 12. Further, the Hon’ble Supreme Court, in Bhadar Ram (Dead) Through Legal Representatives v. Jassa Ram and others, (2022) 4 SCC 259 , while dealing with the case of Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra (supra) has categorically held that the specification of a caste or tribe under Articles 341 and 342 of the Constitution is always in relation to a particular State or Union Territory, and the benefits attached thereto cannot be extended automatically to another State, by observing as under :- “15. In the case of Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra and Another (supra) after considering the decision of this Court in the case of Marri Chandra Shekar Rao (supra) the question arose, Whether a person belonging to caste or tribe specified for the purpose of Constitution to be Scheduled Caste or a Scheduled Tribe in relation to State A migrates to State B, where a caste or tribe with the same nomenclature is specified for the purposes of Constitution to be a Scheduled Caste or Scheduled Tribe in relation to that State B, will that person be entitled to claim the privileges and benefits admissible to persons belonging to Scheduled Caste and /or Scheduled Tribe in State B Holding that a person belonging to Scheduled Caste /Scheduled Tribe in relation to his original State of which he is permanent or an ordinarily resident cannot be deemed to be so in relation to any other State on his migration to that State for the purpose of employment, education etc. 16. In paragraph Nos.3 and 16 it is observed and held as under: “3. On a plain reading of clause (1) of Articles 341 and 342 it is manifest that the power of the President is limited to specifying the castes or tribes which shall, for the purposes of the Constitution, be deemed to be Scheduled Castes or Scheduled Tribes in relation to a State or a Union Territory, as the case may be. On a plain reading of clause (1) of Articles 341 and 342 it is manifest that the power of the President is limited to specifying the castes or tribes which shall, for the purposes of the Constitution, be deemed to be Scheduled Castes or Scheduled Tribes in relation to a State or a Union Territory, as the case may be. Once a notification is issued under clause (1) of Articles 341 and 342 of the Constitution, Parliament can by law include in or exclude from the list of Scheduled Castes or Scheduled Tribes, specified in the notification, any caste or tribe but save for that limited purpose the notification issued under clause (1), shall not be varied by any subsequent notification. What is important to notice is that the castes or tribes have to be specified in relation to a given State or Union Territory. That means a given caste or tribe can be a Scheduled Caste or a Scheduled Tribe in relation to the State or Union Territory for which it is specified. These are the relevant provisions with which we shall be concerned while dealing with the grievance made in this petition.” * * * 16. We may add that considerations for specifying a particular caste or tribe or class for inclusion in the list of Scheduled Castes/Schedule Tribes or backward classes in a given State would depend on the nature and extent of disadvantages and social hardships suffered by that caste, tribe or class in that State which may be totally non est in another State to which persons belonging thereto may migrate. Coincidentally it may be that a caste or tribe bearing the same nomenclature is specified in two States but the considerations on the basis of which they have been specified may be totally different. So also the degree of disadvantages of various elements which constitute the input for specification may also be totally different. Therefore, merely because a given caste is specified in State A as a Scheduled Caste does not necessarily mean that if there be another caste bearing the same nomenclature in another State the person belonging to the former would be entitled to the rights, privileges and benefits admissible to a member of the Scheduled Caste of the latter State "for the purposes of this Constitution". This is an aspect which has to be kept in mind and which was very much in the minds of the Constitutionmakers as is evident from the choice of language of Articles 341 and 342 of the Constitution. That is why in answer to a question by Mr Jaipal Singh, Dr Ambedkar answered as under: "He asked me another question and it was this. Supposing a member of a Scheduled Tribe living in a tribal area migrates to another part of the territory of India, which is outside both the scheduled area and the tribal area, will he be able to claim from the local Government, within whose jurisdiction he may be residing the same privileges which he would be entitled to when he is residing within the scheduled area or within the tribal area It is a difficult question for me to answer. If that matter is agitated in quarters where a decision on a matter like this would lie, we would certainly be able to give some answer to the question in the form of some clause in this Constitution. But so far as the present Constitution stands, a member of a Scheduled Tribe going outside the scheduled area or tribal area would certainly not be entitled to carry with him the privileges that he is entitled to when he is residing in a scheduled area or a tribal area. So far as I can see, it will be practicably impossible to enforce the provisions that apply to tribal areas or scheduled areas, in areas other than those which are covered by them….. ” Relying on this statement the Constitution Bench ruled that the petitioner was not entitled to admission to the medical college on the basis that he belonged to a Scheduled Tribe in the State of his origin.” * 18. The reasoning given by this Court in the case of Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra and Another (supra) are on interpretation and on a plain reading of Clause I of Articles 341 and 342 of the Constitution of India, which are referred to hereinabove. The reasoning given by this Court in the case of Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra and Another (supra) are on interpretation and on a plain reading of Clause I of Articles 341 and 342 of the Constitution of India, which are referred to hereinabove. We see no reason to restrict the applicability of the decision of this Court in the case of Action Committee on Issue of Caste Certificate to Scheduled Castes and Scheduled Tribes in the State of Maharashtra and Another (supra) only with respect to employment, education or the like and not to make applicable the same with respect to purchase and sale of the property in case of sale and purchase of the land belonging to a Scheduled Caste person in the State of Rajasthan and when the said land was allotted to the original land owner – Chunilal as Scheduled Caste landless person. 19. At this stage, it is required to be noted that in the subsequent decision in the case of Ranjana Kumari (supra), a Three Judge Bench of this Court had an occasion to consider the same issue. Before this Court the appellant belonged to Valmiki Caste (Scheduled Caste of the State of Punjab), who married a person belonging to Valmiki Caste of Uttarakhand migrated to that State. It was found that in the State of Uttarakhand also under the Presidential order ‘Valmiki’ was also recognized as notified Scheduled Caste. Even the State of Uttarakhand also issued a certificate to the appellant. However, the State of Uttarakhand denied the benefit, which may be available to the Scheduled Caste belonging to State of Uttarakhand. Thereafter the appellant approached the High Court. The High Court rejected the claim. The decision of the High Court was carried before this Court. While dismissing the Appeal, it is observed in paragraph 4 as under: (SCC p. 665) “4. Two Constitution Bench judgments of this Court in Marri Chandra Shekar Rao Vs. Dean, Seth G.S. Medical College & Ors. and Action Committee on Issue of Caste Certificate to Scheduled Castes & Scheduled Tribes in the State of Maharashtra & Anr. Vs. Union of India & Anr. have taken the view that merely because in the migrant State the same caste is recognized as Scheduled Caste, the migrant cannot be recognized as Scheduled Caste of the migrant State. and Action Committee on Issue of Caste Certificate to Scheduled Castes & Scheduled Tribes in the State of Maharashtra & Anr. Vs. Union of India & Anr. have taken the view that merely because in the migrant State the same caste is recognized as Scheduled Caste, the migrant cannot be recognized as Scheduled Caste of the migrant State. The issuance of a caste certificate by the State of Uttarakhand, as in the present case, cannot dilute the rigours of the Constitution Bench Judgments in Marri Chandra Shekar Rao (supra) and Action Committee (supra).” 13. The aforesaid principle, though initially expounded in the context of Scheduled Castes and Scheduled Tribes, has been consistently held to apply with equal force to Other Backward Classes as well. The constitutional scheme underlying reservation recognises that social and educational backwardness is neither uniform nor static across the country but is intrinsically linked to local conditions prevailing in a particular State or Union Territory. The identification of Other Backward Classes is, therefore, undertaken independently by each State on the basis of contemporaneous socio-economic data, local disadvantages, and relative backwardness within that State. Consequently, the mere inclusion of a caste in the list of Other Backward Classes in one State does not ipso facto entitle a person belonging to such caste to claim reservation benefits in another State, unless such caste is also duly recognised and notified as backward in the latter State in accordance with the applicable statutory and constitutional framework. Any contrary interpretation would defeat the very object of reservation and undermine the State-specific nature of affirmative action envisaged under Articles 15(4), 15(5) and 16(4) of the Constitution of India. 14. Very Recently, the Hon’ble Supreme Court has reaffirmed the aforesaid position in Chandigarh Housing Board v. Tarsem Lal , (2025) 5 SCC 503 , wherein it was reiterated that reservation benefits are strictly confined to the State or Union Territory for which the caste is notified and held as follows :- “23. 14. Very Recently, the Hon’ble Supreme Court has reaffirmed the aforesaid position in Chandigarh Housing Board v. Tarsem Lal , (2025) 5 SCC 503 , wherein it was reiterated that reservation benefits are strictly confined to the State or Union Territory for which the caste is notified and held as follows :- “23. Thereafter, the Constitution Bench of this Court in Bir Singh [Bir Singh v. Delhi Jal Board, (2018) 10 SCC 312 : (2019) 1 SCC (L&S) 1] , being seized of the dispute pertaining to SC/ST reservation for persons who had migrated to the National Capital Territory of Delhi, reiterated the well-settled principles enunciated in Marri Chandra Shekhar Rao [Marri Chandra Shekhar Rao v. Seth G.S. Medical College, (1990) 3 SCC 130 ] and Action Committee [Action Committee on Issue of Caste Certificate to SCs/STs v. Union of India, (1994) 5 SCC 244 ] in the following words : (Bir Singh case [Bir Singh v. Delhi Jal Board, : (2019) 1 SCC (L&S) 1] , SCC pp. 344-46, paras 34 & 36) “34. Unhesitatingly, therefore, it can be said that a person belonging to a Scheduled Caste in one State cannot be deemed to be a Scheduled Caste person in relation to any other State to which he migrates for the purpose of employment or education. The expressions “in relation to that State or Union Territory” and “for the purpose of this Constitution” used in Articles 341 and 342 of the Constitution of India would mean that the benefits of reservation provided for by the Constitution would stand confined to the geographical territories of a State/Union Territory in respect of which the lists of Scheduled Castes/Scheduled Tribes have been notified by the Presidential Orders issued from time to time. A person notified as a Scheduled Caste in State ‘A’ cannot claim the same status in another State on the basis that he is declared as a Scheduled Caste in State ‘A’. *** 36. The upshot of the aforesaid discussion would lead us to the conclusion that the Presidential Orders issued under Article 341 in regard to Scheduled Castes and under Article 342 in regard to Scheduled Tribes cannot be varied or altered by any authority including the Court. It is Parliament alone which has been vested with the power to so act, that too, by laws made. It is Parliament alone which has been vested with the power to so act, that too, by laws made. Scheduled Castes and Scheduled Tribes thus specified in relation to a State or a Union Territory does not carry the same status in another State or Union Territory. Any expansion/deletion of the list of Scheduled Castes/Scheduled Tribes by any authority except Parliament would be against the constitutional mandate under Articles 341 and 342 of the Constitution of India.” * * * * 29.2. This implies that a person belonging to a group that is recognised as a Scheduled Tribe in a State would be recognised a Scheduled Tribe only within the said State and not in a UT where he migrates if no such Presidential Notification exists in the said UT.” 15. Reverting to the facts of the present case in the light of aforementioned rulings of the Hon’ble Supreme Court, it is quite vivid that the advertisement issued by the Chhattisgarh Vyapam left no manner of doubt that the eligibility conditions for availing reservation benefits were mandatory in nature. Clause 8(A) of the advertisement specifically required the candidate to possess and produce a permanent caste certificate issued by the competent authority of the State of Chhattisgarh. The requirement was not merely procedural but went to the very root of eligibility. Admittedly, the petitioner failed to submit a caste certificate issued in strict conformity with the provisions of the Chhattisgarh Scheduled Castes, Scheduled Tribes and Other Backward Classes (Regulation of Social Status Certification) Act, 2013 and the rules framed thereunder at the relevant point of time. 16. The caste certificate relied upon by the petitioner was issued for a limited purpose, namely, employment under the Central Government, and the certificate itself clearly records such restricted validity. A certificate issued for a specific purpose and jurisdiction cannot be expanded or utilised dehors the conditions expressly mentioned therein. Reliance upon such certificate for securing appointment under the State of Chhattisgarh was, therefore, legally impermissible. The appointment obtained by the petitioner against a reserved category post was consequently in direct contravention of the terms of the advertisement as well as the statutory scheme governing social status certification within the State. 17. The submission advanced on behalf of the petitioner that her entitlement to reservation does not lapse on account of marriage or migration, though attractive at first blush, cannot be accepted in law. 17. The submission advanced on behalf of the petitioner that her entitlement to reservation does not lapse on account of marriage or migration, though attractive at first blush, cannot be accepted in law. The issue is not the loss of caste identity but the entitlement to State-specific reservation benefits, which flows exclusively from a valid and legally recognised caste certificate issued by the competent authority of that State. Mere recognition of a caste as Other Backward Class in another State, or even its inclusion in the Central List, does not automatically entitle a candidate to claim reservation in the migrated State unless all statutory and regulatory requirements of that State are duly complied with. The law in this regard is settled that migration by itself does not carry reservation benefits. 18. As regards the plea of violation of principles of natural justice, this Court is unable to agree with the submissions advanced on behalf of the petitioner. The record unambiguously reveals that the petitioner was served with a show-cause notice clearly indicating the deficiencies in her caste certificate and the proposed action. She was afforded adequate opportunity to submit her explanation, which was duly considered by the competent authority before taking the impugned decision. The action taken is thus founded on objective assessment of relevant material and adherence to due process and cannot be characterised as arbitrary or unfair. 19. This Court is conscious of the limited scope of interference in exercise of its writ jurisdiction under Article 226 of the Constitution of India. Where the action of the respondents is shown to be in conformity with statutory provisions and supported by well-settled principles of law laid down by the Hon’ble Supreme Court, this Court would be slow to interfere, particularly in matters involving eligibility and conditions of service. In the absence of any perversity, illegality or jurisdictional infirmity, re-appreciation of facts is wholly unwarranted. 20. Having regard to the totality of facts and circumstances of the case, and in view of the settled legal position governing State- specific reservation benefits, this Court is of the considered view that the petitioner has failed to establish any enforceable legal right so as to warrant interference by this Court under Article 226 of the Constitution of India. 21. Accordingly, the writ petition fails and is hereby dismissed . No order as to costs.