“De Minimis Non Curat Lex: The Supreme Court emphasised that Law does not concern itself with trifles
Case title: Vashist Narayan Kumar vs The state of Bihar & Ors.
Case no.: Civil Appeal No. 1 of 2024
Decided on: 02.02.2024
Quorum: Hon’ble Justice J.K Maheshwari, Hon’ble Justice K.V Viswanathan
FACTS OF THE CASE:
The appellant applied for the position of police constable and took the written and physical examinations. He provided his educational certificates/mark sheets, as well as his caste certificate, for document verification. On June 11, 2018, the final results indicated that he had failed. The only reason was that his date of birth was 08.12.1997 on the online application form, but 18.12.1997 on the school mark sheet. After failing to receive a response, the appellant filed a writ petition in the High Court. The High Court dismissed his writ petition challenging this decision.
ISSUES:
Whether the error in the uploaded application form was material or trivial, and was the State justified in declaring the appellant to have failed as a result?
APPELLANTS CONTENTION:
The appellant contended that he derived no advantage because he was eligible regardless of which date was used; the error also had no bearing on the selection, and he produced educational certificates that reflected his correct date of birth despite being unaware of it.
RESPONDENTS CONTENTION:
The respondent contended that the advertisement contained all of the clauses stating that if the information provided by the candidates was incorrect or misleading, the application form would be rejected, and criminal action would be taken. It also stated that candidates must enter the correct date of birth as shown on their 10th board certificate. The clause also stated that candidates must correctly fill out their name, father’s name, address, and other information on the application form. It states that if any discrepancy is discovered while reviewing the documents, the candidate’s candidature will be cancelled.
COURT ANALYSIS AND JUDGEMENT:
The court determined that the appellant successfully completed all stages of the selection process. The error in the application was trivial and had no bearing on the selection process. The State’s exaggeration of the situation was unjustified.
The court stated that they did not believe the appellant could be penalised for this minor error that had no bearing on the final outcome. Errors of this nature, as seen in the present case, do not constitute misrepresentation or wilful suppression.
The court emphasised the principle of De minimis non curat lex, which states that trivial errors or omissions are exceptions because the law does not deal with trifles.
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Written by – Surya Venkata Sujith