Punjab & Haryana HC Dismisses Diploma Student's Plea to Relax PSPCL Cut-Off Date for Junior Engineer Recruitment

A diploma student who had one exam pending challenged PSPCL's cut-off date for its Junior Engineer/Electrical recruitment; the High Court upheld the condition as constitutionally valid and dismissed the writ petition.

The High Court of Punjab and Haryana at Chandigarh has dismissed a writ petition filed by Manpreet Kaur, a Diploma in Electrical Engineering student, who sought to challenge the eligibility cut-off date prescribed by the Punjab State Power Corporation Limited (PSPCL) for recruitment to 622 posts of Junior Engineer/Electrical. Justice Harpreet Singh Brar, sitting singly, held on 27 May 2026 that the condition requiring candidates to possess the requisite qualification by the last date of submission of online applications — 10 May 2026 — was neither arbitrary nor violative of Articles 14 and 16 of the Constitution of India. The court found the condition to be a well-entrenched legal principle rooted in equality, fairness, and administrative efficiency, and declined to interfere in exercise of extraordinary writ jurisdiction under Articles 226 and 227.

The Recruitment Advertisement and the Petitioner's Position

PSPCL issued Advertisement No. CRA-316/26 dated 13 April 2026 inviting online applications for 622 posts of Junior Engineer/Electrical. The last date for submission of online applications was fixed as 10 May 2026. Note (iii) under Clause 2 of the eligibility criteria permitted candidates who had appeared or were appearing in the relevant examination and whose result was awaited to apply, but made it mandatory that such candidates acquire the requisite qualification by the last date of submission of online applications and produce proof thereof.

Manpreet Kaur was pursuing a Diploma in Electrical Engineering from a recognised institution and had completed all semesters of the course as well as mandatory industrial training and internship. However, due to what she described as unavoidable circumstances, she could not appear in one examination. That examination was scheduled for June 2026, with the final result and certificate expected only in July or August 2026.

On 7 May 2026, three days before the application deadline, the petitioner submitted a representation to PSPCL seeking clarification and provisional permission to apply. She also forwarded the representation by email the same day. No response was received before the deadline. To protect her candidature, she submitted the online application form on 9 May 2026, mentioning approximate aggregate marks calculated from her completed semesters. She later learnt that candidates with results awaited were required to select the “Result Awaited” option in the application form rather than entering marks.

What the Petitioner Sought from the Court

The writ petition made six prayers. The petitioner sought a writ of certiorari to quash Note (iii) under Clause 2 of the eligibility criteria insofar as it fixed the last date of online application as the cut-off date for possessing the requisite qualification. She also sought writs of mandamus directing PSPCL to treat the date of document verification or any subsequent stage of the recruitment process as the relevant cut-off date, to accept her application and permit her to participate in the examination, and to refrain from rejecting her candidature.

Additionally, she sought a direction permitting her to edit or correct her online application form, or alternatively to have her candidature considered despite having entered approximate marks rather than selecting the “Result Awaited” option. She also sought a direction to PSPCL to decide her representation dated 7 May 2026 by a reasoned and speaking order within a time-bound manner.

The constitutional challenge rested on Articles 14 and 16. Counsel for the petitioner argued that fixing the application submission date as the cut-off was self-contradictory and arbitrary, particularly when the recruitment examination and document verification were yet to be conducted. It was submitted that the condition unjustly excluded deserving candidates who were on the verge of acquiring the qualification well before the completion of the selection process.

PSPCL's Defence of the Eligibility Condition

Counsel for PSPCL contended that the terms and conditions of Advertisement No. CRA-316/26 were binding and sacrosanct and had to be strictly adhered to by all candidates. Any candidate who did not fulfil the eligibility criteria as on the stipulated cut-off date automatically became ineligible. It was argued that the eligibility conditions could not be diluted or relaxed by the court in exercise of writ jurisdiction, particularly since they applied uniformly to all aspirants.

PSPCL further argued that the petitioner admittedly did not possess the requisite qualification as on 10 May 2026, and that no enforceable or vested right accrued in her favour merely because she had submitted an application. Mere participation in the recruitment process or filing of an application, it was submitted, does not confer any indefeasible right of appointment or even consideration unless all eligibility conditions are satisfied.

How the Court Reasoned

Justice Harpreet Singh Brar found no ambiguity in Note (iii) under Clause 2 of the advertisement. The provision plainly required candidates with results awaited to acquire the requisite qualification by the last date of submission of online applications and to produce proof thereof. The court held that the condition prescribing the application submission date as the cut-off could not be characterised as arbitrary, unreasonable, or violative of Articles 14 and 16. Fixation of a cut-off date, the court observed, has a reasonable nexus with the object of ensuring certainty, uniformity, and finality in the recruitment process. The terms of an advertisement are binding on all candidates equally and cannot be altered midway to confer advantage on a particular candidate.

The court acknowledged that the petitioner was likely to acquire the qualification at a later stage but held that this did not entitle her to seek relaxation of the eligibility conditions. It observed that the practice of prescribing a cut-off date for acquiring essential qualifications is a well-entrenched legal principle rooted in constitutional values of equality, fairness, non-arbitrariness, and administrative efficiency. The recruitment process would be rendered open-ended and disorderly if time frames were not demarcated for achieving milestones.

The court relied on two decisions of the Supreme Court. The first was a two-Judge bench decision in Bhupinderpal Singh and others v. State of Punjab, (2000) 5 SCC 262, where Justice R.C. Lahoti, speaking for the bench, held that the cut-off date by reference to which eligibility must be satisfied is the date appointed by the relevant service rules, or if no such date is appointed by the rules, then the date fixed in the advertisement, or failing that, the last date for receipt of applications. The bench in that case also observed that a loose practice of determining eligibility by reference to the date of interview — which had been prevalent in Punjab — must be treated as having been brought to an end, since it created confusion and uncertainty in the selection process.

The second decision was a more recent one: Rajasthan Public Service Commission v. Lavanshu Sankhla & others, decided by the Supreme Court on 4 May 2026 in SLP (Civil) No. 32964 of 2025. That case directly addressed whether the relevant date for acquiring the minimum essential qualification is the date of submission of the application or any time prior to the commencement of the interview process. The Supreme Court held that the relevant date is the date of submission of the application, since eligibility is assessed on the basis of particulars and documents furnished at that stage and there is no provision for subsequent supplementation. The Supreme Court in that case also declined to adopt the approach that, where two interpretations are possible, the one favourable to candidates should be preferred, holding that the language of the advertisement admitted of only one clear and unambiguous interpretation.

Justice Brar also referred to the two-Judge bench decision in Ashok Kumar Sharma v. Chander Shekhar, (1997) 4 SCC 18, which stated that

Outcome

Finding no merit in the writ petition, Justice Harpreet Singh Brar dismissed it on 27 May 2026. The court held that no ground was made out for interference in exercise of extraordinary writ jurisdiction under Articles 226 and 227 of the Constitution of India. All pending miscellaneous applications, if any, were also disposed of. The court recorded that the order is a speaking and reasoned one, and marked it as reportable.