1. The Petitioner instituted the present Writ Petition filed under Article 226 and 227 of the Constitution of India, 1950, challenging the action of the Opposite Parties in refusing to accept the Petitioner’s application for participation in the recruitment process for the post of Management Trainee Human Resource, MT(HR) pursuant to Advertisement No. OHPC: HQ: HRD: RECTT:02/2025, dated- 07.11.2025, despite the Petitioner fulfilling all the prescribed eligibility criteria as stipulated in the said advertisement.

I. FACTUAL MATRIX OF THE CASE:

2. The brief facts of the case culled out from the pleadings:

                  (i) Opposite Party No.2, Odisha Hydro Power Corporation Ltd. (OHPCL), issued Advertisement No. OHPC: HQ: HRD: RECTT:02/2025 dated 07.11.2025, inviting applications for recruitment to the posts of Management Trainees (MTs) and Diploma Engineers Trainees (DETs) in various disciplines, for induction and subsequent deployment at different units and project sites of the Corporation.

                  (ii) Applications for the aforesaid posts were invited exclusively through online mode, and the relevant application link was hosted on the official website of Opposite Party No.2, namely www.ohpcltd.com The online application portal remained open from 12.11.2025 to 11.12.2025.

                  (iii) The advertisement, under Clause (F), clearly prescribed the age eligibility criteria, stipulating a minimum and maximum age limit of 18 to 32 years for candidates applying for the post of DETs, and 21 to 32 years for candidates applying for the post of MTs. It further provided for relaxation of the upper age limit by 5 years for candidates belonging to SC/ST/SEBC/Women categories and 10 years for candidates belonging to the PwD category, notwithstanding that no vacancy was specifically earmarked for the SEBC category.

                  (iv) The Petitioner, being a BBA graduate with an MBA qualification and belonging to the SEBC (reserved) category, found himself fully eligible for the post of Management Trainee (HR) under the unreserved category, in terms of the eligibility conditions stipulated in the advertisement, and accordingly submitted his application through the online portal within the stipulated time.

                  (v) Upon submission of the online application, an auto-generated Unique Registration Number, i.e., OHPCL25013790, was initially allotted to the Petitioner. However, subsequently, the Opposite Parties declined to accept the Petitioner’s application on the purported ground of over-age, thereby rejecting his candidature without lawful justification.

                  Aggrieved by the foregoing inaction of the Opposite Party No.2, the Petitioner has been constrained to file the present Writ Petition.

II. SUBMISSIONS ON BEHALF OF THE PETITIONER:

3. The learned counsel for the Petitioner respectfully and earnestly made the following submissions in support of his contentions:

                  (i) Odisha Hydro Power Corporation Ltd. (OHPCL) issued Advertisement No. OHPC: HQ: HRD: RECTT:02/2025, dated 07.11.2025, inviting applications for recruitment to the posts of Management Trainees (MTs) and Diploma Engineer Trainees (DETs) in various disciplines.

                  (ii) The Petitioner is a BBA graduate with an MBA qualification and belongs to the reserved category, i.e., SEBC. In terms of the eligibility conditions, including age criteria and educational qualifications prescribed in the said advertisement, the Petitioner was fully eligible for consideration for the post of Management Trainee (HR) under the unreserved category, as the advertisement did not prohibit candidates belonging to reserved categories from competing for unreserved posts.

                  (iii) Pursuant to the said advertisement, the Petitioner applied for the aforesaid post through the online application link hosted on the official website of OHPCL. Upon initiation of the online application process, an auto-generated Unique Registration Number, i.e., OHPCL25013790, was allotted to the Petitioner. However, while the Petitioner was in the process of completing and submitting the online application form, the online portal failed to accept the application, displaying a pop-up message stating "over-age" as the reason for rejection, notwithstanding the fact that the Petitioner fell within the upper age limit after availing the age relaxation expressly provided to SEBC candidates under the advertisement.

                  (iv) Aggrieved by the abrupt rejection of his application, the Petitioner made inquiries through the OHPC Help Desk telephone number provided in the advertisement. The Petitioner was informed by the concerned officials that his online application could not be accepted on the ground that no vacancy had been earmarked for the SEBC category, and that for the said reason, his candidature stood rejected, even though he had applied against an unreserved vacancy.

                  (v) The Petitioner possesses all the qualifications required for the post of MT(HR) and being a member of the SEBC category, is eligible for the upper age limit relaxation as prescribed under Clause F(iii) of the said advertisement. To buttress this argument, reliance was placed on the Supreme Court’s observation in Union of India & Ors v. Sajib Roy (AIR 2025 SC 4158) , wherein it was noted that in Jitendra Kumar Singh & Anr. v. State of U.P. & Ors ((2010) 3 SCC 119) , the court was called upon to decide the whether availing relaxation in fees or in the upper age limit by candidates belonging to the reserved category would disentitle them from being considered for appointment against unreserved seats. The Bench held that such relaxations in fee or age were incidental and ancillary provisions to the core concept of reservation. These concessions were merely an ‘aid to reservation’ and enabled the reserved category candidates to participate in open competition on merit. The Court further observed that such concessions did not affect the level-playing field in the recruitment process, as both reserved and unreserved categories continue to compete with each other on equal footing, without any undue advantage.

                  (vi) It is apposite to state that, even in the absence of a specific vacancy reserved for the SEBC Category, the Petitioner, being a member of the said category, remains entitled to the benefit of age relaxation and is eligible to participate in the recruitment process under the unreserved category in terms of the provisions of the aforesaid advertisement.

III. SUBMISSIONS ON BEHALF OF THE OPPOSITE PARTIES:

4. Per contra, the learned counsel for the Opposite Parties earnestly made the submission that the present Writ Petition is not maintainable before this Court and deserves to be rejected in limine.

                  (i) The Opposite Party submits that the Petitioner has no indefeasible right to seek consideration for appointment in contravention of the terms and conditions stipulated in the recruitment advertisement. It is contended that the recruitment advertisement constitutes the governing framework of the selection process, and the eligibility criteria, conditions, and instructions contained therein are binding both on the recruiting authority as well as on all candidates participating in the selection process.

                  (ii) The Opposite Parties further contend that Clause F(iii) of the advertisement stipulates relaxation of the upper age limit by five years for candidates belonging to SC/ST/SEBC/Women/Ex-Servicemen and by ten years for candidates belonging to the PwD category. However, placing reliance on Clause G of the advertisement, the Opposite Parties submit that the concessions meant for SEBC candidates are admissible only to SEBC candidates of Odisha, and that reservation is to be applied strictly in accordance with the provisions of the Odisha Reservation of Vacancies (ORV) Act and the Rules framed thereunder, with category-wise vacancies expressly specified in Clause A of the advertisement.

                  (iii) It is the specific stand of the Opposite Parties that, since no vacancy has been earmarked for the SEBC category, the benefit of upper age relaxation contemplated under Clause F(iii) of the advertisement cannot be extended to candidates applying against unreserved posts, in the absence of any express statutory rule or provision in the advertisement permitting what is described as “category-based relaxation without corresponding reservation.”

                  (iv) The Opposite Parties further submit that when a candidate belonging to a reserved category seeks consideration against an unreserved post, such candidate is required to satisfy all eligibility conditions applicable to the unreserved category, and cannot claim age relaxation or other category-specific concessions, unless such benefit is expressly provided for under the applicable recruitment rules or the terms of the advertisement. In other words, the migration of a reserved category candidate to the unreserved category is permissible only in accordance with, and subject to, explicit statutory or contractual authorization governing the recruitment process.

                  (v) The issue stands authoritatively settled by the Hon’ble Supreme Court in Union of India & Ors. Vs. Sajib Roy (supra), wherein the Court examined the permissibility of consideration of candidates belonging to reserved categories against unreserved vacancies. The Hon’ble Court has held that such consideration, commonly referred to as migration of a reserved category candidate to the unreserved category, is not an automatic or inherent right, but must be expressly sanctioned either by the applicable recruitment rules or by the terms and conditions contained in the recruitment notification.

                  (vi) The Supreme Court has further clarified that, in the absence of any express statutory provision or an explicit clause in the recruitment advertisement permitting such migration, a candidate belonging to a reserved category and seeking appointment against an unreserved post is required to satisfy all eligibility conditions applicable to the unreserved category,  without  claiming  any  category-specific concessions. Accordingly, the permissibility and extent of such migration are to be determined strictly on the basis of the governing recruitment rules and the express stipulations contained in the recruitment notification, and cannot be inferred by implication or assumed by analogy.

                  (vii) Relying upon the aforesaid principles, the Opposite Parties further submit that neither the applicable recruitment rules nor the terms of the recruitment advertisement authorize the grant of age relaxation to SEBC candidates when they are not competing against posts reserved for the SEBC category. It is contended that the provision relating to age relaxation merely acknowledges the entitlement of SEBC candidates to such relaxation within the framework of reservation, and therefore must be read harmoniously with the category-wise vacancy matrix expressly specified in the advertisement. In the absence of any vacancy earmarked for the SEBC category, the Opposite Parties assert that the benefit of age relaxation cannot be extended to candidates applying against unreserved posts.

                  (viii) The Opposite Parties further contend that matters pertaining to recruitment policy, including the fixation of age limits, determination of category-wise vacancies, and the grant or denial of relaxations, lie predominantly within the policy domain of the employer and the State. It is submitted that judicial interference in such matters is impermissible unless the decision-making process is shown to suffer from manifest arbitrariness, perversity, or a patent illegality of a brazen nature.

IV. COURT’S REASONING AND ANALYSIS:

5. Heard Learned Counsel for parties and perused the documents placed before this Court.

6. In light of the foregoing facts and rival submissions, the primary issue that arises for consideration before this Court is whether the Petitioner, who was declared ineligible for applying to the post of Management Trainee (Human Resources) under the impugned recruitment advertisement, is legally entitled to participate in the recruitment process for the said post.

7. It is observed that Opposite Party No.2 issued Advertisement No. OHPC: HQ: HRD: RECTT:02/2025 dated 07.11.2025, inviting online applications for recruitment to the posts of Management Trainees (MTs) and Diploma Engineer Trainees (DETs), prescribing detailed eligibility conditions, including age limits and permissible relaxations. In so far as the post of Management Trainee (Human Resources) is concerned, the advertisement notified four (4) vacancies, namely three (3) Unreserved (UR) and one (1) Scheduled Tribe (ST), with no vacancy earmarked for the SEBC category in the said cadre.

8. It is further observed that, in the present case, the Petitioner was 35 years and 5 months of age as on the relevant cut-off date prescribed in the recruitment advertisement. The Petitioner sought consideration for appointment against the Unreserved category, for which the maximum age limit stipulated in the notification is 32 years which is without any relaxation expressly provided for Unreserved candidates.

9. On a plain, literal, and textual reading of the eligibility conditions stipulated in the recruitment advertisement, the Petitioner would ordinarily be regarded as over-aged for consideration against the Unreserved posts. The vital question, however, arises for consideration is whether the Petitioner, by virtue of belonging to the SEBC category, is entitled to avail the benefit of age relaxation provided under Clause F(iii) of the advertisement while competing for an Unreserved vacancy. Similar issue was confronted by the Supreme Court in the Union of India v. Sajib Roy, (2025 SCC Online SC 1943) , wherein it has been held that:

                  “15. Given this situation, the High Court erred in mechanically applying the ratio in Jitendra Kumar Singh & Anr v. State of U.P. & Ors to the present case without appreciating the difference in the factual matrix of the present case with the cited authority. While in instructions dated 25.03.1994 expressly permitted reserved candidates who have availed relaxation in fees/upper age limit etc. to be considered for appointment in unreserved category, office memorandum dated 01.07.1998 clearly barred such migration in the event the reserved candidates had availed in age, experience qualification, etc.”

10. In the present case, the migration of a candidate belonging to a reserved category to the Unreserved category is permissible only if such migration is expressly authorized by the applicable recruitment rules or by the terms of the recruitment advertisement. Where the recruitment notification either expressly prohibits or does not contemplate such migration, the benefit of age relaxation or other category-based concessions cannot be invoked to circumvent the prescribed eligibility conditions applicable to Unreserved posts. Any attempt to avail such relaxation in the absence of enabling provisions would render the candidate ineligible for consideration against the Unreserved category. It is often observed by the Constitutional Courts that the formulation of recruitment policy, including the fixation of age limits, category-wise vacancies and grant of relaxation, squarely falls within the exclusive domain of the employer. This Court, in exercise of its jurisdiction under Article 226 of the Constitution of India, would refrain from interfering with the same.

11. It is further stated that the online application portal automatically applies the prescribed age eligibility criteria to all applicants on the basis of their date of birth, declared category, and the category-wise vacancies notified in the advertisement. In the present case, the Petitioner’s application was rejected at the threshold on the ground of being over-aged, with reference to the age limit applicable to the Unreserved category. Moreover, the advertisement itself expressly stipulated that no vacancy was earmarked for the SEBC category in the cadre of Management Trainee (HR) and that age relaxation could not be availed in the absence of a specific vacancy for the concerned category, thereby leaving no scope for discretionary or ad hoc application of relaxations.

12. This Court is of the considered view that, in the present case, the prescribed age limit for candidates belonging to the Unreserved category for the post of Management Trainee (Human Resources), as stipulated under Clause F(ii) of the recruitment advertisement, requires that a candidate must not be below 21 years and must not have attained the age of 32 years as on 01.08.2025.

13. Admittedly, the Petitioner exceeds the upper age limit prescribed for the Unreserved category and is, therefore, ineligible for consideration against the said category. Furthermore, the recruitment advertisement unequivocally discloses that no vacancy has been earmarked for the SEBC category in the concerned cadre. In the absence of any post reserved for the said category, the Petitioner cannot, as a matter of right, claim the benefit of age relaxation applicable to SEBC candidates. Accordingly, the Petitioner is not entitled to seek such relaxation when no vacancy exists for his category under the recruitment notification.

                  V. This Court is also of the considered view that a judicial pronouncement must be read and understood in the context of the facts of the case in which it is rendered, as each case turns on its own distinct and distinguishable factual matrix. The ratio decidendi of a decision cannot be mechanically or abstractly applied, divorced from the factual and statutory context that shapes the judgment. If the relief sought by the Petitioner were to be granted in the present case, it would result in hostile and unconstitutional discrimination among candidates competing in the Unreserved category, thereby violating the guarantees of equality and equal opportunity in public employment enshrined under Articles 14 and 16 of the Constitution of India.

VI. CONCLUSION:

14. In view of the foregoing analysis, and upon an anxious and careful consideration of the material facts and circumstances of the case, this Court is of the considered view that the Petitioner is not entitled to apply for the post in question. It is reiterated that the migration of a candidate belonging to a reserved category to the Unreserved category is permissible only where such migration is expressly contemplated under the applicable recruitment rules or the terms of the recruitment advertisement. In the absence of any such enabling provision in the present case, the Petitioner cannot claim consideration for age relaxation against the Unreserved category. Consequently, this Court finds no merit in the Writ Petition and is not inclined to grant the reliefs prayed for. Accordingly, the Writ Petition stands dismissed.

15. Interim order, if any, passed earlier stands vacated.