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Mandeep Singh & Ors. v. State of Punjab and Ors.

Civil Appeal · 2025 INSC 834Decided 14 Jul 2025
C.A. No.-009471-009471 - 2025 (with connected appeals from SLP(C) Nos. 23141, 23324 of 2024 and 907 of 2025)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

The State of Punjab initially requisitioned the Punjab Public Service Commission to recruit 931 Assistant Professors and 50 Librarians for government degree colleges, and the Commission engaged subject experts and began preparatory work. After a change of government in September 2021, the entire process was altered: the State bypassed the Commission and instead created two departmental selection committees (run by two state universities) to fill not just the newly sanctioned posts but all 1091 Assistant Professor and 67 Librarian posts, based purely on a written test, without ever getting Council of Ministers' approval for the change. Candidates and other affected persons challenged this in the Punjab and Haryana High Court, and a Single Judge quashed the entire recruitment for violating the 2010 UGC Regulations (adopted by Punjab in 2013) and for wrongly excluding the Public Service Commission. A Division Bench of the High Court reversed the Single Judge and upheld the recruitment, prompting the affected candidates to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court traced the historical and constitutional role of Public Service Commissions as institutions designed to keep public recruitment free of political interference and favoritism, and held that posts falling within the Commission's purview under Article 320 read with the Punjab Public Service Commission (Limitation of Functions) Regulations, 1955 cannot simply be diverted to ad hoc departmental committees without valid justification. It found that the State's stated reasons for bypassing the Commission and departing from the applicable UGC Regulations were not genuine administrative necessities but were driven by narrow political considerations following the change in government, and that the State failed to show the departure from the standard recruitment norm was based on any rational, non-arbitrary principle. While acknowledging the hardship this would cause to already-selected candidates, the Court held there was no equity in their favour since the recruitment was challenged while still pending and all appointments were expressly made subject to the outcome of the litigation. It therefore allowed the appeals, set aside the Division Bench's judgment, quashed the entire recruitment process, and directed the State to conduct a fresh recruitment following the UGC Regulations of 2018 now in force.

Lesson Learnt

Government cannot bypass a constitutionally mandated Public Service Commission or applicable UGC recruitment norms for political convenience; and candidates who accept selection or appointment while litigation challenging that very recruitment is pending cannot later claim equitable protection if the process is ultimately found illegal.

Official source (sci.gov.in)View Judgment (PDF)

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