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Salary Income Cannot Be Clubbed for OBC-NCL Reservation Eligibility: Madras HC 

Case Law Details

TaxGuru Citation
2026 taxguru.in 6932
Case Name
Jenesh Sathees Mathew Vs District Collector (Madras High Court)
Date of Judgement/Order
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Jenesh Sathees Mathew Vs District Collector (Madras High Court)

The petitioner challenged the order dated 27.05.2026 rejecting his request for an OBC-Non Creamy Layer (OBC-NCL) certificate and sought a direction to issue the certificate based on his appeal dated 21.05.2026.

The petitioner contended that he had been issued an OBC certificate for the year 2024-2025, but the present application was rejected on the ground that his father’s salary exceeded the prescribed income limit. He relied upon the Supreme Court’s judgment in Civil Appeal Nos. 2827-2829 of 2018 dated 11.03.2026, which clarified that, under the Income/Wealth Test contained in Category VI of the 1993 Office Memorandum, income from salaries and agricultural land should not be clubbed with income from other sources while determining exclusion from OBC reservation benefits.

The respondents submitted that the petitioner had failed to enclose his father’s income certificate while applying for the certificate. According to the status report, the petitioner’s father’s income exceeded Rs.87 lakhs and, therefore, the petitioner was not entitled to the OBC certificate.

The Madras High Court observed that the petitioner had not submitted the income certificate and other supporting documents along with the application, which led the authorities to conclude that the income exceeded the prescribed limit. The Court permitted the petitioner to submit a fresh application along with the income certificate, income tax particulars, and a copy of the Supreme Court judgment. It directed the third respondent to reconsider the application on its merits, taking into account the income certificate and the Supreme Court guidelines, and to pass appropriate orders on or before 10.06.2026. The writ petition was accordingly disposed of without costs.

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Author Info

CA Sandeep Kanoi
Qualification: CA in Job / Business
Company: Taxguru Consultancy
Location: Mumbai, Maharashtra
Articles Published: 21,136

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