Rajasthan HC Dismisses CLAT Candidate's Plea to Switch Reservation Category After Deadline
A Jaipur student who omitted to claim Rajasthan domicile reservation in her CLAT 2026 form could not correct the omission after results were declared, the Rajasthan High Court has ruled.
Justice Maneesh Sharma, sitting singly at the Jaipur Bench of the High Court of Judicature for Rajasthan, dismissed a writ petition filed by Darshita Gupta, a 17-year-old Jaipur resident, who sought to alter her reservation category in the CLAT 2026 admission process from “Unreserved – Women” to “General Category – Rajasthan Domicile (GC-RJ)” after the result was declared and counselling had commenced. The court held that permitting such a change would erode the sanctity of the admission process and defeat the purpose of prescribing a strict deadline for corrections, particularly where the omission was the candidate's own. The order was reserved on 3 September 2026 and pronounced on 10 September 2026.
How the Dispute Arose
Darshita Gupta passed her Senior Secondary Examination (CBSE) in 2025 and applied to appear in the Common Law Admission Test (CLAT) 2026, conducted by the Consortium of National Law Universities for the five-year integrated undergraduate law course. While filling the online application form, she applied under the Unreserved (General) Category and claimed reservation under the ‘Women’ category. She did not claim reservation under the GC-RJ (Rajasthan Domicile) category.
The Consortium's press release dated 20 July 2025 had notified 31 October 2025 as the last date for submission of applications. A further notification dated 5 November 2025 provided candidates an opportunity to correct their application forms on or before 11:59 p.m. on 9 November 2025, after which “no requests for changes to information provided in the CLAT 2026 Application Form will be entertained.” The petitioner did not avail of either window to claim the GC-RJ category.
The CLAT 2026 examination was held on 7 December 2025. Darshita secured 94.25 marks, an All India Rank (AIR) of 649 in the General Category, and a category rank of 309 in the Women category. After the first round of counselling, the Consortium published a provisional list showing that the last candidate selected against the GC-RJ category for NLU, Jodhpur had secured AIR 562. On realising that her candidature was not being considered under the State domicile category, she sent an e-mail dated 8 January 2026 to Respondent No. 1, attributing the omission to an inadvertent error or technical glitch, enclosing her domicile certificate, and requesting that a domicile rank be assigned to her.
The Consortium declined the request by reply e-mail of the same date, 8 January 2026, stating that since she had not applied under the Rajasthan Domicile category in her original form, her reservation category could not be altered at a belated stage after expiry of the stipulated deadline. The petitioner's grievance deepened when the provisional second list showed that the last candidate selected against the GC-RJ category in the second round of counselling had secured AIR 654 — a rank lower than her own AIR of 649.
The writ petition was filed assailing the e-mail/order dated 8 January 2026. A Co-ordinate Bench, by interim order dated 11 February 2026, directed that one seat be kept vacant for the petitioner at NLU, Jodhpur if any candidate lower in merit had been accorded admission or a seat was lying vacant. NLU, Jodhpur, by its communication dated 7 August 2026, confirmed that one seat had been kept vacant in compliance with that direction.
The matter was listed on an interlocutory application filed by the respondents seeking vacation of the interim order. With the consent of counsel for both sides, the writ petition itself was taken up for final disposal on merits.
The Legal Question
The core question before the court was whether a candidate who omitted to claim reservation under the GC-RJ (Rajasthan Domicile) category in her original application form could be permitted to change her reservation category after expiry of the correction deadline and after declaration of the result.
Counsel for the petitioner, Mr. Abhishek Sharma, contended that the denial was arbitrary given that she holds a valid domicile certificate and that candidates with lower ranks had been selected under the GC-RJ category. He further relied on Clause 1.5.1.4 of the Notification dated 17 December 2025, which, he argued, permitted a candidate to update her preferences for the desired university any number of times until the closure of counselling registration. He also pointed to the vacant seat at NLU, Jodhpur kept pursuant to the interim order.
Counsel for the respondents, Mr. Rishabh Khandelwal, and counsel for Respondent No. 4, submitted that the refusal was consistent with policy applied uniformly to all candidates and that the petitioner had missed both the application deadline of 31 October 2025 and the correction window closing on 9 November 2025. A change of category sought in January 2026, after results were declared, could not be entertained.
How the Court Reasoned
Justice Maneesh Sharma held that the petitioner's request for post-facto correction, sought nearly two months after the last date for correction of applications, was “plainly an afterthought and cannot be permitted.”
On the argument based on Clause 1.5.1.4, the court read the clause narrowly. It found that the liberty granted under that provision is confined to updating a candidate's “preferences” — such as the choice and order of participating National Law Universities during counselling registration — and does not confer any right to alter, amend, or modify the category of reservation claimed in the application form after the prescribed cut-off date.
The court drew on a consistent line of authority across courts. It referred to the Division Bench judgment of this court at the Principal Seat, Jodhpur in Piyush Kaviya & Ors. v. The Rajasthan Public Service Commission & Ors. (D.B. Special Appeal Writ No. 198/2018, dated 10 April 2018), which reasoned that the balance between merit and public interest in timely filling of posts is struck by providing a window period for corrections, and that candidates who remain negligent during that window cannot seek relief thereafter. The court also applied the Delhi High Court's ruling in Ms. Aadya Yadav v. Union of India & Anr. (W.P. (C) 496/2021, dated 13 January 2021), which held that permitting a category change after results are declared would wreak unforeseen consequences on other candidates and disrupt the entire admission schedule.
The Kerala High Court's judgment in Govardhan S. v. CLAT Consortium of NLU & Anr. (W.P. (C) No. 290/2023, dated 22 June 2023) was also cited for the proposition that claims under reserved categories are considered only if the candidate had claimed the same in the original online application.
At the level of the Supreme Court, the court relied on J. & K. Public Service Commission v. Israr Ahmad ((2005) 12 SCC 498), which held that a selection process constitutes an integrated continuum and that a candidate who qualifies in a particular category at the preliminary stage cannot alter that status at a later stage. The status of a candidate must remain consistent throughout. The court also cited Rajasthan High Court, Jodhpur and Ors. v. Neetu Harsh and Ors. ((2021) 11 SCC 383), where the Supreme Court held that a candidate who fails to claim reservation at the initial stage and omits to furnish the requisite certificate cannot claim the benefit of a reserved category after selection. The Punjab and Haryana High Court's ruling in Parwinder Singh v. State of Punjab & Ors. (D.B. Civil Writ Petition No. 6761/2023) was noted to similar effect.
The court stated plainly that where a window period is provided for rectification of errors, a corresponding duty of vigilance is cast upon the candidate to ensure her particulars are correct. An inadvertent error or negligence cannot be cured by invoking the extraordinary writ jurisdiction under Article 226 of the Constitution of India, particularly where doing so would override deadlines applied uniformly to all candidates.
On the vacant seat argument, the court was direct. The seat had been kept vacant solely in compliance with the interim order of 11 February 2026, as a protective measure, and subject to final adjudication. That interim order did not cure the fundamental defect in the petitioner's application form, nor did it confer any substantive right to a seat reserved for a category under which she had never applied.
The court also addressed and distinguished the two Division Bench judgments cited by the petitioner — Indra v. Union of India & Ors. (D.B. Civil Writ Petition No. 15529 of 2025, dated 16 September 2025) and Reena Choudhary v. State of Rajasthan & Ors. (D.B. Special Appeal Writ No. 1175 of 2024, dated 2 January 2025). In those cases, the Division Benches were concerned with the rectification of inadvertent errors of a trivial nature. The present case involved a belated alteration of the reservation category itself, which has a direct and cascading effect on the merit list, on the displacement of other selected candidates, and on the ultimate allotment of seats. The judgments were held to be distinguishable on facts.
Outcome
The court held that the rejection of the petitioner's candidature under the GC-RJ category by the Consortium suffered from no legal infirmity or perversity warranting interference under Article 226 of the Constitution of India. The writ petition was dismissed with no order as to costs. All pending applications were disposed of. The court noted separately that D.B. SAW/1150/2026 has been filed in the matter and that further orders should be referred to that proceeding.