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Prabhjot Kaur v. State of Punjab and Others

Civil Appeal · 2025 INSC 479Decided 9 Apr 2025
C.A. No.-005132-005132-2025 (arising out of SLP(C) No. 17747 of 2023)
Justice Sudhanshu Dhulia · Justice K. Vinod Chandran

Background

The Punjab Public Service Commission advertised posts including one for Deputy Superintendent of Police (DSP) reserved for "Scheduled Caste Sports" candidates. After new rules mandating 33% reservation for women came into force, the State withdrew the original advertisement and issued a fresh one in which the sole DSP post in that category was reserved for "SC Sports (Women)". Prabhjot Kaur, the only woman who qualified in that category, expected to be appointed DSP, but a male candidate (K. Munivenkatappa, referred to as the private respondent) who topped the same category among men challenged the women's-only reservation, relying on a roster system notified after the application deadline, and the Punjab and Haryana High Court's Division Bench sent the matter back for fresh consideration.

Decision Breakdown

The Supreme Court held that the terms of the operative advertisement (issued 11.12.2020) governed the recruitment, and a roster system notified afterward (in January 2021) could not retroactively change reservation criteria after applications had closed and the process was underway. Relying on the principle that "rules of the game" cannot be changed once a recruitment process starts, as reaffirmed by a Constitution Bench in Tej Prakash Pathak v. High Court of Rajasthan (2025). The Court held that the DSP post remained validly reserved for "SC Sports (Women)" and Prabhjot Kaur, being the only qualified woman in that category, was entitled to the appointment. The Division Bench's order remanding the matter was set aside and the Single Judge's order in the appellant's favour was restored.

Lesson Learnt

Once a government recruitment advertisement fixes the eligibility and reservation criteria and the process of applying begins, those terms cannot be changed midway to the disadvantage of candidates who applied under the original terms: a principle citizens can rely on if a public recruitment process is altered after they've already applied.

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

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