Screening Criteria Aiming At Selecting All-Rounded Candidates Not Violative Of Articles 14 & 16: Punjab & Haryana High Court Dismisses Petition Challenging HSPC’s Exam Scheme

The petition before the High Court was filed under Articles 226, 227 seeking quashing of the scheme/pattern of exam for the screening test as laid down in the announcement for the post of Assistant Environmental Engineer in the respondent Haryana State Pollution Control Board.

The Single Bench of Justice Harpreet Singh Brar held, “It would not meet the objective standards of logic and justice if the Courts step into the shoes of domain experts and substitute their conclusions with its own. The demands of the job and nature of interactions it forces can only be most accurately predicted by the employer. Therefore, the establishing screening criteria aiming at selecting all-rounded candidates cannot be held to be violative of Articles 14 and 16 of the Constitution.”

Advocate A.S. Nirmaan represented the Petitioner while Advocate Kanwal Goyal represented the Respondent.

Arguments

As per the petitioner, the examination is being conducted by the respondent-HPSC in three steps- screening test, subject knowledge test and interview. However, the syllabus prescribed for the screening test outrightly excludes the subjects relevant to engineering. It was the petitioner’s case that the screening test criterion does not test the candidates on their knowledge in the subjects relevant to the post and has no rational nexus with the advertised post. It was further submitted that testing the candidates on their general knowledge, history etc, does not serve any purpose as the post of Assistant Environmental Engineer has a technical nature.

It was the case of HPSC that with respect to the notification of the year 2023, a total of 7189 applications were received against 54 posts. However, on completion of the process, only 25 candidates were recommended for appointment, leaving 29 posts vacant. Since over half of the posts were left vacant, it was decided to simplify the syllabus for the screening test by including general topics and the advertisement in question was issued with respect to the said 29 posts. It was submitted that the candidates seeking appointment to Group B posts are expected to have basic general knowledge and analytical skills to discharge their duties in a proper fashion, and it cannot be said that testing them on general subjects is arbitrary.

Reasoning

Noting that the general trend in recruitment to government jobs continues to rely heavily on bookish knowledge, the Bench said, “Such an approach often fails to account for creativity, adaptability, emotional intelligence and other such skills that are essential for effective administration, especially in the context of public service.It is certainly a welcome step when the authorieties responsible for recruitment look beyond the traditional norms and adopt a process that attempts to gauge a candidate’s overall intelligence quotient and situational judgment. Such selection processes are more likely to appoint well-rounded public servants capable of nuanced application of the knowledge.”

The Bench further added, “Thus, general knowledge exams go beyond testing memory and delve into the field of analytical comprehension ensuring that the candidate can identify issues, connect diverse subjects, predict consequences and make informed decisions.” The Bench also reaffirmed that Courts must not to interfere in recruitment process when the advertisement qua the same is clear and within the legal framework. It is the prerogative of the employer to lay down an eligibility criterion as it alone can best judge suitability of a candidate for the advertised role.

Coming to the facts of the case, the Bench noted that he respondent-HPSC chose to make a policy modification by changing the screening test syllabus in view of the significant backlog of vacancies from the recruitment process of the year 2023. Noitng the petitioner’s argument against exclusion of engineering subjects from the screening test, the Bench mentioned, “...a candidate does not have a vested right to be subjected to the exact same standards of the last recruitment cycle. Further, allowing candidates to instruct the recruiting agency regarding examination pattern and eligibility criteria would have an unwarranted contagion effect, much to the detriment of all stakeholders. It must also be noted that the candidates are due to be subjected to a subject knowledge test once they qualify for it by obtaining a generous 25% marks in the screening test.”

Thus, finding no merit in the petitioner’s arguments and submissions, the Bench dismissed the petition and further held that the impugned action of the respondent-HPSC did not suffer from any legal infirmity warranting interference under Articles 226/227 of the Constitution of India.

Cause Title: Amit Ahalawat v. State of Haryana (Neutral Citation: 2025:PHHC:149766)

Appearance

Petitioner: Advocate A.S. Nirmaan

Respondent: Advocates Kanwal Goyal, Mansi, Sukhdeep S. Parmar

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