MP High Court Upholds MP Police SI Recruitment Rules on Horizontal Reservation Cut-Offs

In Dharmu Khapariye and Others v. State of Madhya Pradesh and Others, the Madhya Pradesh High Court upheld the 2025 amendment to the Madhya Pradesh Police Executive (Non-Gazetted) Service Recruitment Rules, 1997, clarifying that no separate cut-off marks are required for horizontally reserved categories at the preliminary examination stage of the Police Sub-Inspector recruitment process.

A Division Bench comprising Chief Justice Sanjeev Sachdeva and Justice Vinay Saraf dismissed a batch of petitions filed by police constables and ex-servicemen challenging the January 24, 2025 amendment and the MP Police SI Recruitment Rule Book, 2025.

The petitioners argued that the absence of separate preliminary cut-offs for ex-servicemen and police constables diluted the benefit of horizontal reservation and prevented adequate representation at later stages of selection.

They relied on judgments including Indra Sawhney v. Union of India and Rajesh Kumar Daria v. Rajasthan Public Service Commission. The Court, however, held that horizontal reservations operate as “interlocking reservations” within vertical categories and do not create separate compartments requiring independent cut-offs. The Bench observed that the preliminary examination is merely a screening process and not a stage for final merit determination.

Referring to Supreme Court jurisprudence, the Court reiterated that candidates selected under horizontal reservation must ultimately be accommodated within their respective vertical categories. The Bench further noted that the recruitment rules specifically provide that horizontal reservation benefits are to be applied at the later stage of selection and not during the preliminary examination itself.

The Court also rejected reliance on judgments relating to Persons with Disabilities reservation, holding that those rulings arose from a distinct statutory framework under the Rights of Persons with Disabilities Act, 2016.

Holding that the amendment merely clarifies the recruitment process and does not violate Articles 14 or 16 of the Constitution, the High Court dismissed all petitions without costs.