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Tina Dabi Case Cited as Jabalpur High Court Stays MPPSC 2025 Mains Over Reservation Rule Dispute

The rule mandates that candidates who avail any form of reservation-related relaxation—except exam fee or travel allowance—must remain within their category throughout the recruitment process
Indian Masterminds Stories

The Jabalpur High Court has stayed the Madhya Pradesh Public Service Commission (MPPSC) State Service Examination 2025 Mains, following two petitions (9253 and 11444/2025) challenging the constitutional validity of Rule 4 of the MP State Service Examination Rules, 2015. This rule mandates that candidates who avail any form of reservation-related relaxation—except exam fee or travel allowance—must remain within their category throughout the recruitment process and cannot be shifted to the unreserved category based on merit.

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The issue will come up for a crucial hearing on May 6, where the General Administration Department (GAD), Bhopal, is expected to defend the rule. Officials have prepared a detailed response and will cite various Supreme Court judgments, including the well-known Tina Dabi case. Ms. Dabi, who topped the UPSC Civil Services Exam in 2015, had cleared the Prelims under the SC category cutoff. Despite becoming the overall topper with 1063 marks in the Mains, she was allotted a seat under the SC category and not shifted to unreserved due to her use of the category-based relaxation in Prelims.

Other Supreme Court verdicts, such as Deepi vs Union of India and Jitendra Singh vs Union of India (2010), are also being cited by the government to establish that category-shifting after using reservation benefits is impermissible. The Department of Personnel and Training (DoPT) has similar guidelines, which Madhya Pradesh has adopted.

Rule 4, introduced under a 2000 notification during Mr. Digvijaya Singh’s tenure as CM, has long governed MPPSC recruitments. It stipulates that reserved category candidates availing any non-fee related exemptions (such as age relaxation or lower cut-offs) must stay in that category during all phases—Prelims, Mains, Interviews, and Final Merit.

The petitions not only challenge Rule 4 but also seek quashing of the 2000 gazette notification and the 2025 MPPSC exam notification that references this rule.

In its submission to the High Court, MPPSC revealed that out of 1140 candidates selected under the unreserved category, 690 were from reserved categories: 42 SC, 5 ST, 381 OBC, and 262 EWS—selected purely based on merit. Only 450 candidates were from the general category.

Category-Wise Prelims Cut-Off for 2025:

  • UR: 158
  • SC: 142
  • ST: 128
  • OBC Male: 154
  • OBC Female: 152
  • Provisional (13%): UR – 152, OBC – 150

So far, 3866 candidates (87%) have been declared successful in the prelims, and 828 candidates in the remaining 13% for the mains before the stay order was issued.

The outcome of the May 6 hearing could significantly shape future recruitment policies and impact thousands of aspirants awaiting clarity.

Also Read: Telangana High Court Dismisses Retired IPS T. Prabhakar Rao’s Plea for Protection from Arrest in Telephone Tapping Case


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