Haryana Staff Selection Commission Case: Supreme Court Upholds High Court Verdict on B.Ed Eligibility

The Supreme Court of India recently ruled on the case Haryana Staff Selection Commission vs. Priyanka & Others, addressing the rejection of candidates for the post of Post-Graduate Teachers (PGT) due to provisional or confidential B.Ed results. The Court upheld the High Court’s verdict that as long as the authenticity of the provisional result was confirmed by the university, it was a valid qualification for eligibility.

The Haryana Staff Selection Commission (HSSC) had issued an advertisement on 28.06.2015 for PGT positions, requiring candidates to have completed a B.Ed degree by the last date of application, which was 12.10.2015. Several candidates who had appeared for the B.Ed examination but had not received their final results submitted their applications with provisional results issued by their respective universities.

Background of the Case

The case revolved around the HSSC’s rejection of candidates who had received their provisional B.Ed results but had not yet been issued final results by their universities before the cutoff date. The affected candidates challenged this rejection through writ petitions, which were allowed by the Single Judge of the High Court. The Division Bench later affirmed this decision.

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Aggrieved by the High Court’s ruling, HSSC filed a Special Leave Petition before the Supreme Court.

Arguments by the Appellant (Haryana Staff Selection Commission)

• HSSC contended that the eligibility requirement specified that the candidate should have passed B.Ed by the last date of application (12.10.2015).
• It argued that a provisional/confidential result issued before that date could not be considered an officially declared final result.
• HSSC maintained that allowing candidates with provisional results to apply would set a problematic precedent for future recruitment processes.

Arguments by the Respondents (Candidates)

• The candidates argued that their universities had provided them with official provisional results before the application deadline.
• They contended that there was no dispute regarding the authenticity of these results, which were later confirmed by their respective universities.
• The respondents pointed out that denying them the opportunity based on mere procedural delays by the universities was unjust and deprived them of rightful employment.

Supreme Court’s Key Observations

• The Court emphasized that as long as the authenticity of the provisional results was not in doubt and was later confirmed by the universities, the candidates could not be considered ineligible.
• The Court upheld the High Court’s ruling that the candidates were indeed qualified on the cutoff date, as their universities had declared their provisional results before 12.10.2015.
• The bench found no merit in HSSC’s argument that provisional results should not be considered as valid proof of qualification.

Quashing of High Court’s Advisory on Rule Amendments

While upholding the High Court’s verdict, the Supreme Court set aside the High Court’s additional directive advising HSSC to amend its rules to determine eligibility based on the date of screening or interview rather than the application deadline.

On this aspect, the Supreme Court stated:

“Such directions, as have been issued by the High Court, were not necessary in the present case. As such, in our opinion, since the said question was not in issue, the High Court ought not to have directed as aforesaid. We, thus, quash the aforesaid directions.”

Final Verdict and Order

• The Supreme Court dismissed HSSC’s appeals and upheld the High Court’s decision in favor of the candidates.
• HSSC was directed to offer appointments to 90 candidates (74 private respondents and 16 intervenors who had filed applications before 27.11.2018) within four weeks.
• The Court clarified that these candidates would be placed below already appointed candidates in seniority and would receive no salary for the period they were not in service.

Thus, the ruling ensures that deserving candidates, who had legitimately completed their qualifications before the deadline, are not unfairly denied employment due to procedural delays by their universities.

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Petitioner Name: Haryana Staff Selection Commission.
Respondent Name: Priyanka & Others.
Judgment By: Justice Vineet Saran, Justice Dinesh Maheshwari.
Place Of Incident: Haryana.
Judgment Date: 01-09-2021.

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