Haryana Staff Selection Commission Ordered to Appoint Eligible Candidates: Supreme Court Ruling

The Supreme Court of India, in the case of Haryana Staff Selection Commission v. Priyanka & Others, delivered an important ruling on May 9, 2022, directing the Haryana Staff Selection Commission (HSSC) to offer appointments to eligible candidates who had obtained provisional B.Ed. results before the cut-off date. The judgment ensures that procedural formalities do not unjustly disqualify eligible candidates and upholds the merit-based selection process.

Background of the Case

The dispute arose from the HSSC’s recruitment process for the post of Post-Graduate Teachers (PGT) in different disciplines. The advertisement, issued on June 28, 2015, required candidates to possess a B.Ed. degree on or before October 12, 2015, which was the last date for submitting applications.

Certain candidates had appeared for the B.Ed. examination and received their provisional or confidential results from their universities before the cut-off date. However, the HSSC rejected their applications on the ground that their final results had not been officially declared by the respective universities before October 12, 2015.

The affected candidates challenged this rejection before the Punjab and Haryana High Court. A Single Judge of the High Court ruled in their favor on October 23, 2017, holding that a provisional result obtained directly from the university could not be disregarded. The Division Bench of the High Court upheld this decision, leading to an appeal before the Supreme Court.

Key Legal Issues

Whether candidates with provisional B.Ed. results obtained before the cut-off date were eligible for selection.
Whether HSSC was justified in rejecting applications on the ground that final results were not declared before the cut-off date.
Whether candidates who had secured provisional results before October 12, 2015, but were not considered, should be offered appointments.

Arguments by the Haryana Staff Selection Commission

The HSSC, represented by its counsel, argued:

The eligibility criteria mandated that candidates must have a final B.Ed. degree before the cut-off date.
The rejection of candidates with provisional results was consistent with established recruitment norms.
Changing the eligibility criteria after the recruitment process would create inconsistencies and lead to litigation.
The High Court’s ruling would set a precedent requiring recruitment agencies to accept provisional certificates in all cases.

Arguments by the Respondents (Candidates)

The candidates, represented by Senior Advocate Priyanka, countered:

Their B.Ed. results were issued by universities before the cut-off date and should be considered valid.
The HSSC had failed to account for delays caused by universities in issuing final degree certificates.
The High Court’s decision was correct in holding that provisional results issued by recognized universities were legally valid.
Many of them had already appeared for the screening test based on provisional eligibility and should not be disqualified retrospectively.

Supreme Court’s Observations

The Supreme Court examined the issue in light of previous judgments and the principle of fairness in recruitment. The Court noted:

“The result obtained by the writ petitioners could not have been considered invalid, as the same was obtained not from any other source but from the university itself.”

The Court further stated:

“If some candidates did not bother to apply for confidential results, they are to blame themselves for the said lapse. Those who were vigilant and had applied for confidential results before the cut-off date should not be penalized.”

The Supreme Court also emphasized the role of universities in ensuring timely issuance of results, observing:

“Many times, universities, due to administrative reasons, delay the declaration of results. Candidates seeking employment or further admission should not be made to suffer for such delays.”

Final Judgment

The Supreme Court upheld the High Court’s decision and directed HSSC to:

Offer appointments to 90 candidates who had obtained provisional results before the cut-off date.
Ensure that these candidates are placed just below those who were already appointed in the recruitment process.
Fix the seniority of these candidates based on inter se merit.
Consider similarly placed candidates whose cases were pending before the High Court.

The Court clarified that these candidates would not be entitled to back wages for the period they had not worked but would receive notional benefits for seniority and increments.

Key Takeaways from the Judgment

The ruling affirms that provisional results issued by universities before the cut-off date must be considered valid for recruitment purposes.
The Court rejected rigid procedural barriers that unjustly disqualify candidates due to administrative delays by universities.
HSSC was directed to comply with merit-based selection principles while rectifying past recruitment errors.
The judgment establishes that eligibility disputes in recruitment must be resolved in favor of fairness and transparency.

Conclusion

The Supreme Court’s ruling in Haryana Staff Selection Commission v. Priyanka & Others ensures that meritorious candidates are not disqualified due to procedural technicalities. By directing the appointment of eligible candidates who had obtained their B.Ed. results before the cut-off date, the Court has reinforced the principle that recruitment agencies must act fairly and transparently.

This judgment serves as a precedent for future recruitment disputes, emphasizing that procedural formalities should not unjustly deprive deserving candidates of employment opportunities.

Petitioner Name: Haryana Staff Selection Commission.
Respondent Name: Priyanka & Others.
Judgment By: Justice Dinesh Maheshwari.
Place Of Incident: Haryana.
Judgment Date: 09-05-2022.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: haryana-staff-select-vs-priyanka-&-others-supreme-court-of-india-judgment-dated-09-05-2022.pdf

Directly Download Judgment: Directly download this Judgment

See all petitions in Recruitment Policies
See all petitions in Employment Disputes
See all petitions in Public Sector Employees
See all petitions in Judgment by Dinesh Maheshwari
See all petitions in allowed
See all petitions in Modified
See all petitions in supreme court of India judgments May 2022
See all petitions in 2022 judgments

See all posts in Service Matters Category
See all allowed petitions in Service Matters Category
See all Dismissed petitions in Service Matters Category
See all partially allowed petitions in Service Matters Category