In September 2025, the Central Administrative Tribunal (CAT) quietly delivered what may become one of the most important judgments for persons with Specific Learning Disabilities (SLD) in India’s civil services. The case of Molshree Aggarwal & Sonalika Aggarwal v. UPSC & Ors., is more than just another legal battle over reservation. It’s a story of two women with dyslexia who refused to accept bureaucratic exclusion as fate.
Molshree and Sonalika Aggarwal, sisters from Delhi, both have benchmark SLD certifications (above 40%) recognized under the Rights of Persons with Disabilities (RPwD) Act, 2016. Both are exceptionally accomplished; one is a graduate from Lady Shri Ram with six years of experience at Bloomberg, and the other a distinction holder from St. Stephen’s College. Both aspired to join the Indian Civil Services.
Yet, despite the RPwD Act’s clear mandate of 4% reservation; including 0.5% for persons with disabilities like autism, intellectual disability, mental illness, and SLD, they found themselves completely excluded from reservation in the Civil Services Examination (CSE).
When the 2024 CSE notification came out, it left out category (d) candidates (which includes SLD) from any reserved posts. Ironically, the same rules that denied them reservation did grant them age relaxation; an inconsistency the Tribunal later described as “non-application of mind.”
How this exclusion worked
The exclusion stemmed from a series of bureaucratic notifications and circulars. A 2021 DEPwD notification failed to identify even a single post in the Civil Services as suitable for category (d) disabilities. A DoPT Office Memorandum (OM) laid down uniform “Functional Classification and Physical Requirements,” excluding this category. In December 2024, another DEPwD OM extended this exclusion till 2027, all based on an “Expert Committee” that, shockingly, had no experts on learning disabilities.
When Molshree was denied reservation in CSE 2024, she complained to the Chief Commissioner for Persons with Disabilities (CCPD) and her complaint was dismissed, without explanation. So, she and her sister approached the CAT.
Arguments of the Petitioner and the Government
The Petitioner has argued that the government was violating Section 34 of the RPwD Act, which mandates 4% reservation in government jobs, including 1% for category (d) disabilities.
This argument was based on the fact that no posts had been identified for SLD, despite the legal requirement, and the exemptions were arbitrary, mechanical, and unsupported by data. They also contended that the government had failed to identify suitable posts, denied reasonable accommodation, and made arbitrary policy decisions without consulting experts or the CCPD, as the law required. Moreover, it was pointed out that denying reservation while granting age relaxation is irrational. The respondents in this case included the UPSC, DoPT and DEPwD. They claimed that the exclusion was based on policy decisions and expert recommendations. They argued that courts shouldn’t interfere in such policy matters, especially when the candidates had already participated in the exam “without protest.” In short, the bureaucratic line was that this was not discrimination, but procedure.
What the tribunal found
In a detailed and empathetic judgment delivered on 25 September 2025, the Bench of Mr. Manish Garg (J) and Dr. Anand S. Khati (A) dissected every aspect of the exclusion.
The tribunal held that this exclusion violated the law. Section 34’s reservation mandate is statutory and binding. The Tribunal found that the government had not consulted the CCPD as required, nor provided any data to justify its decision. The exemption was not “exceptional” as the law allows; it was opaque, and arbitrary. Candidates with SLD could easily perform most non-technical civil service roles, especially with aids like scribes or assistive technology. Other bodies, like the RBI and SSC, had already identified such posts; so the exclusion wasn’t about feasibility, but mindset.
The government argued that these policy decisions were based on the expert committee, the tribunal however, found that the decision-making process itself was flawed. The so-called Expert Committee lacked SLD specialists and extended exclusions mechanically for three years. The Tribunal noted that the internal files showed a “predetermined intent to exclude,” with no evidence-based reasoning.
The tribunal also observed that the government has contradicted itself by granting age relaxation to SLD candidates but denying reservations. This reflected “non-application of mind.”
In perhaps the most moving part of the judgment, the Bench acknowledged that learning disabilities are a reflection of intellectual limitations, yes, but also of socially constructed barriers; even referencing globally recognized individuals with SLD to underline the point.
In arriving at its conclusions, the Tribunal drew upon strong jurisprudential foundation. It cited the Supreme Court’s decisions in Vikash Kumar v. UPSC (2021) and Ravinder Kumar Dhariwal v. Union of India (2023), both of which affirmed that reasonable accommodation is an enforceable right, not a matter of discretion. It invoked National Federation of the Blind (2013), which held that the failure to identify posts cannot defeat the statutory mandate of reservation. It relied on Jeeja Ghosh (2016), where denial of reasonable accommodation was recognized as a form of discrimination, and Shayara Bano (2017), where the Court struck down laws on grounds of manifest arbitrariness.
Beyond statutory interpretation, the judgment rested on constitutional guarantees of equality under Article 14, dignity under Article 21, and the freedom to pursue one’s profession under Article 19(1)(g). The Tribunal reiterated that while policy decisions deserve deference, courts must intervene when the policy-making process itself is arbitrary, exclusionary, or unsupported by evidence.
The tribunal declared the process flawed and issued the following directions:
- The DEPwD’s December 2024 OM (which excluded SLD candidates till 2027) must be reconsidered.
- A High-Powered Committee must be constituted to identify suitable posts for SLDs, involving psychologists, medical experts, and representatives from various ministries.
- The process must be completed before CSE 2026, with reasons and data made public.
- Future exemptions must be specific, justified, and transparent.
The Tribunal, however, did not grant immediate relief to Molshree; even though she ranked second in merit among PwD candidates but lost out because only one post was available. Instead, it focused on systemic reform for future exams.
What this judgement means going forward
The decision stands out for its empathy and precision. It treats reasonable accommodation as a constitutional duty, not administrative generosity. It sees the exclusion of SLD candidates not as a technical matter but as a moral failure of governance. It even gestures towards the need for a national policy on learning disabilities; a long-ignored area of public policy.
At the same time, the judgment’s restraint is also its weakness. By deferring relief to 2026, it leaves the petitioners without immediate justice.
Still, the significance of Molshree Aggarwal cannot be overstated. For the first time, the CAT has explicitly recognized that excluding SLD candidates from the Civil Services violates both the RPwD Act and the Constitution. If implemented sincerely, this could open the bureaucracy to thousands of candidates who have been invisibly filtered out for years. It could also set a precedent for other examinations, from the Staff Selection Commission to public sector banks; to follow suit. The judgment reaffirms a principle too often forgotten in policy debates: that reservation is not largesse but a mechanism of equality. Exemptions must be exceptional, not habitual. The right to reasonable accommodation is not a courtesy; it is a condition of justice.
Haasi Jain and Dhruv Aaigiwal
5th year, B.B.A LL.B (Hon), BML Munjal University School of Law.