Safiya Malik

The High Court of Rajasthan Single Bench of Justice Ashok Kumar Jain disposed of multiple petitions by candidates for Nursing Officer posts seeking consideration under the Outstanding Sportsperson category, holding that the concerned State recruitment authority must examine such claims in line with the Department of Personnel (K-2) circular dated 27 May 2022. The Court stated that scrutiny must proceed on three counts—level of participation, type of event, and performance—and set out five checks: apply the State’s definition of an outstanding sportsperson; verify whether the event was international, national, State, or otherwise covered by policy; confirm recognition of the organising body; assess participation and performance; and verify domicile or category documents where applicable. Petitioners were permitted to submit representations with supporting material within four weeks, after which the authority must decide by a reasoned order and, where eligibility is found, process candidature on merit.

The batch of writ petitions arose from a common grievance relating to recruitment to the post of Nursing Officer pursuant to the advertisement dated 05.05.2023. The petitioners claimed entitlement to consideration under the Outstanding Sports Person category on the basis of sports certificates issued for participation in international, national, state, inter-university, or school-level tournaments. The recruiting authorities declined to treat the petitioners as outstanding sportspersons, primarily on the ground that the organizing sports bodies or federations were not recognized or affiliated with the Indian Olympic Association or did not satisfy the criteria under the applicable State policy.

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The petitioners contended that they had duly submitted certificates evidencing participation in tournaments organized by various sports associations and that their claims were liable to be examined in accordance with the Department of Personnel Circular dated 27.05.2022. Reliance was placed on earlier decisions of Coordinate Benches and Division Benches of the High Court dealing with similar disputes concerning sports quota claims.

The respondents opposed the petitions, asserting that the tournaments and associations relied upon by the petitioners were not recognized under the prevailing policy framework and that the petitioners, therefore, did not fall within the Outstanding Sports Person category. It was submitted that any representation could be examined in accordance with law, but no automatic entitlement to appointment existed.

The Court noted that all the writ petitions raised a common issue and were accordingly disposed of by a single order. It recorded that the petitioners had claimed outstanding sportsperson status “on the basis of their participation in sports tournaments organized by the concerned associations, or sports body.”

After considering the rival submissions, the Court observed that the recruitment authority is required to examine such claims in accordance with the State policy governing outstanding sportspersons. The Court stated that “it is necessary for the recruitment agency or examination body to examine the claim of a candidate who has submitted a certificate of participation in any international, national, State, inter-university or school-level tournament.”

The judgment recorded that such examination must be undertaken “in accordance with the policy of the State as mentioned in the DOP Circular dated 27.05.2022 or as amended from time to time.” The Court further observed that, ordinarily, the claim of an outstanding sportsperson is required to be examined on three parameters, namely “level of participation,” “type of event,” and “performance.”

Elaborating on the process, the Court recorded that the steps include “considering the definition of ‘outstanding sportsperson’ as provided under the recruitment rules or the policy of the State,” “verifying the level of the event,” and “inquiring into the recognition of the organizing body.” It was also noted that performance, participation, and verification of domicile or category conditions are relevant aspects.

The Court took note of earlier decisions of Coordinate and Division Benches, including cases where the Selection Board had sought information from the Indian Olympic Association regarding approved and affiliated sports bodies. It observed that the respondents are under an obligation to examine recognition and affiliation claims “in light of state policy.”

The Court directed that “the respondents shall consider and examine the claim of the petitioner(s) regarding their status as outstanding sportspersons in accordance with the rules and policy of the State, as interpreted by this Court in ratio as referred hereinabove. The petitioner(s) shall be at liberty to submit a representation within a period of four weeks to the respondents, in addition to the claim already made by them, with all supporting documents.”

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 “The respondents shall examine the participation and recognition, including affiliation, strictly in accordance with the policy of the State.” It was clarified that “if the claim of the petitioner(s) is found to be true and correct, the respondents shall consider the candidature of the petitioner(s) under the outstanding sportsperson category, strictly in accordance with the merits of the recruitment process.”

“In case of any deviation or rejection of claim, a reasoned and speaking order shall be passed by the concerned authority and the same shall be communicated to the petitioner(s) by e-mail or through speed post. The petitioner(s) shall be at liberty to re-approach this Court by filing an appropriate writ petition, if so advised.”

Advocates Representing the Parties

For the Petitioners: Mr. Tanveer Ahamad, Advocate; Mr. Iliyas Khan, Advocate; Mr. Mohit Sharma, Advocate; Mr. Laxmikant Malpura, Advocate; Mr. R.P. Saini, Advocate

For the Respondents: Mr. Archit Bohra, Additional Government Counsel; Mr. Prakhar Jain, Advocate

Case Title: Sumitra Runla & Ors. v. State of Rajasthan & Ors.
Neutral Citation: 2025: RJ-JP:51118
Case Number: S.B. Civil Writ Petition No. 234/2025 and connected matters
Bench: Justice Ashok Kumar Jain