CAT
GRANTS RELIEF TO SSC CANDIDATE WHOSE FIRST-AID CERTIFICATE EXPIRED DURING
COVID-19 PANDEMIC
New Delhi, May 14: In a significant judgment
balancing strict recruitment rules with the extraordinary realities of the
Covid-19 pandemic, the Central Administrative Tribunal (CAT), Principal Bench,
New Delhi, has directed the Staff Selection Commission (SSC) to appoint a
candidate whose candidature had earlier been rejected for not possessing a
valid First-Aid certificate on the crucial cut-off date.
The Tribunal passed the
order in Aarti Yadav vs. Staff Selection Commission & Ors., O.A. No.
469/2024, decided on January 9, 2026, by a Bench comprising Justice Manish Garg
(Member-J) and Dr. Anand S. Khati (Member-A). The applicant was represented by
Advocate Ms. Tanya Rose for Mr. Anuj Aggarwal.
The dispute arose after
SSC rejected the candidature of Aarti Yadav for the post of Lady Medical
Attendant under Post Category No. NR16221 on the ground that she did not
possess a valid First-Aid certificate as on the cut-off date of January 1,
2021.
Before the Tribunal,
the applicant argued that her earlier certificate, issued in July 2017, had
expired during the Covid-19 pandemic period, when First-Aid examinations and
renewals were not being conducted by the Indian Red Cross Society. She later
renewed the certificate on March 27, 2021, immediately after examinations
resumed.
The case acquired
significance after communications placed on record from St. John Ambulance
(India) confirmed that, owing to the pandemic, the Delhi Branch had permitted
renewal of First-Aid certificates whose validity expired between March 1, 2020
and December 31, 2021.
Relying on the Supreme
Court’s decision in Deepak Yadav v. Union Public Service Commission, the
Tribunal observed that the pandemic had created exceptional circumstances which
could not be ignored while examining eligibility conditions.
At the same time, the
SSC relied upon the Supreme Court’s Constitution Bench judgment in Ashok
Kumar Sharma v. Chander Shekhar, contending that eligibility conditions
must be strictly satisfied on the prescribed cut-off date and that recruitment
rules could not be relaxed on sympathetic grounds.
After considering both
precedents, the Tribunal held that the peculiar circumstances arising out of
the Covid-19 pandemic justified a limited relaxation in the present case. The
Bench observed that the inability of the applicant to renew the certificate before
the cut-off date was not attributable to her fault, but to the suspension of
examinations during the pandemic period.
The Tribunal ultimately
quashed the rejection of the applicant’s candidature and directed the SSC and
concerned authorities to issue an appointment offer within two months, subject
to fulfilment of other eligibility conditions. The Bench also granted notional
seniority and notional increments, though actual monetary benefits were
directed to accrue only from the date of joining.
Importantly, the
Tribunal clarified that the ruling was rendered in the peculiar facts of the
case and should not be treated as a binding precedent.
Legal observers say the
judgment highlights the judiciary’s continued effort to ensure that deserving
candidates are not denied public employment opportunities because of
disruptions caused by the Covid-19 pandemic, while simultaneously preserving
the sanctity of recruitment rules in ordinary circumstances.
[Aarti Yadav vs. Staff
Selection Commission & Ors., O.A. No. 469/2024, decided on January 9, 2026,
CAT, Delhi]
https://advocateanujaggarwal.com/home.php
Anuj Aggarwal
Advocate
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New Delhi - 110014
483, Block-2, Lawyers Chambers,
Delhi High Court, New Delhi-110003
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Email – anujaggarwal1984@gmail.com
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