Recruitment Authorities Must Ensure Statutory Reservation Framework to include Specific Learning Disabilities (Dyslexia) : CAT on Disability Rights in Civil Services Examination

Court: Central Administrative Tribunal (Principal Bench, New Delhi)
Bench: Manish Garg (Member – Judicial) and Dr. Anand S. Khati (Member – Administrative)
Case No.: O.A. No. 3553/2024
Case Title: Molshree Aggarwal & Anr. v. Union Public Service Commission & Ors.
Date of Order: 25 September 2025 

Background

The matter before the Central Administrative Tribunal arose from a challenge relating to the framework governing reservation for persons with disabilities in the Civil Services Examination conducted by the Union Public Service Commission (UPSC). The applicants, candidates with benchmark disability in the nature of Specific Learning Disability (dyslexia), alleged that the examination framework adopted by the authorities excluded their disability category from the reservation scheme under the Rights of Persons with Disabilities Act, 2016. 

According to the applicants, the authorities had failed to extend the statutory reservation framework to candidates belonging to disability category (d), despite the mandate contained in Section 34 of the RPwD Act. As a consequence, candidates with specific learning disabilities were effectively required to compete in the examination without the benefit of reservation available to other benchmark disability categories.

The applicants argued that the RPwD Act places a clear obligation on public authorities to ensure that recruitment examinations and service frameworks are structured in a manner that enables the effective participation of persons with disabilities. They contended that the exclusion of their disability category from the reservation scheme amounted to discrimination and undermined the statutory guarantees contained in the disability rights legislation.

Key Observations 

The Central Administrative Tribunal emphasised that recruitment frameworks governing access to public employment must operate consistently with the statutory provisions of the RPwD Act. Competitive examinations such as the Civil Services Examination play a decisive role in determining entry into public services, and therefore the governing rules must reflect the legislative mandate regarding disability reservation and inclusion.

The Tribunal examined the policy framework adopted by the authorities, including the Office Memoranda and recommendations of expert committees relating to the identification of suitable disability categories for participation in the Civil Services Examination. The Bench observed that the statutory scheme of the RPwD Act requires the State to ensure meaningful participation of persons with benchmark disabilities in public employment through appropriate identification of posts and implementation of reservation.

The Tribunal further noted that while recruitment authorities possess the power to identify functional requirements of posts, such identification must remain consistent with the statutory objectives of disability rights legislation. Excluding entire categories of disabilities without adequate justification could potentially undermine the principle of equal opportunity in public employment.

Importantly, the Tribunal emphasised that disability rights jurisprudence increasingly recognises the principle of reasonable accommodation and inclusive participation as central components of equality within administrative systems.

Directions Issued

• The Tribunal examined the claims of the applicants regarding exclusion of disability category (d) from the Civil Services Examination framework.

• It directed that the candidature of the concerned applicant be considered for appointment in the event that the candidate placed above her in the merit list does not join within the validity period of the panel. 

• The matter relating to the broader legality of the policy framework governing disability categories in the Civil Services Examination remained subject to further examination in accordance with law.

Commentary

The decision highlights the continuing challenges associated with implementing disability rights within competitive recruitment systems. Public service examinations such as the Civil Services Examination represent one of the most significant gateways to public employment in India, and therefore the design of these frameworks has far-reaching implications for the inclusion of persons with disabilities.

Historically, recruitment systems have often been structured around rigid functional assumptions regarding the abilities required for public service roles. Such assumptions can inadvertently lead to the exclusion of certain disability categories, particularly where institutional frameworks do not adequately account for evolving understandings of disability and accommodation.

By examining the interaction between the statutory mandate of the RPwD Act and the administrative framework governing the Civil Services Examination, the Tribunal engaged with a broader constitutional question regarding equality in access to public employment. Disability rights legislation seeks to ensure that institutional structures evolve to accommodate diverse abilities rather than restricting participation through rigid classification systems.

The decision therefore contributes to the ongoing development of disability rights jurisprudence in India by highlighting the need for recruitment frameworks that align administrative practice with the statutory commitment to inclusion and equal opportunity.

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