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State Can’t Change Recruitment Rules Midway: Punjab & Haryana High Court Restores Fire Operator Removed Over ‘Unrecognized’ Diploma

State Can’t Change Recruitment Rules Midway: Punjab & Haryana High Court Restores Fire Operator Removed Over ‘Unrecognized’ Diploma

Case Name: Ravinder v. State of Haryana and Others

Date of Judgment: 06 May 2026

Citation: CWP-24324-2025

Bench: Justice Sandeep Moudgil

Held: The Punjab and Haryana High Court held that the State authorities cannot alter eligibility conditions after completion of the recruitment process by introducing new lists of “recognized” and “unrecognized” institutions. The Court ruled that where the advertisement merely required a diploma from an institution recognized by “Government/Government of India,” recognition by any State Government would satisfy the condition unless specifically excluded. Consequently, termination of the petitioner’s service on the basis of a subsequently introduced recognition criteria was declared arbitrary and violative of Articles 14 and 16 of the Constitution.

Summary: The petitioner applied under the BCB category pursuant to CET-2022 and participated in the recruitment process initiated through Advertisement No. 3/2023 for various Group-C and Group-D posts, including the post of Fire Operator-cum-Driver. He successfully cleared the Physical Measurement Test, participated in the written examination, and was ultimately declared successful in the final result. Thereafter, he was issued an appointment letter dated 15.03.2024 and joined service.

Subsequently, after declaration of the result, the Haryana Staff Selection Commission issued public notices dated 04.03.2024 and 11.03.2024 introducing lists of “recognized” and “unrecognized” institutions. The petitioner’s institute, namely National Institute of Fire and Safety Engineering, Nagpur, was categorized as “unrecognized.” On that basis, a show cause notice was issued and eventually the petitioner’s appointment was cancelled by order dated 24.07.2025 despite the fact that he had already served for more than one year.

Before the High Court, the petitioner argued that the advertisement only required a diploma from an institution recognized by the Government or Government of India and did not restrict recognition to institutions approved specifically by the Government of Haryana. It was further contended that the respondents illegally changed the eligibility criteria after completion of the recruitment process by introducing fresh lists of recognized and unrecognized institutions midway.

The State defended the action by contending that recognition necessarily meant recognition by the Government of Haryana or the Central Government and that the petitioner’s appointment was merely provisional and subject to verification of eligibility conditions. Reliance was also placed upon earlier judicial precedents emphasizing that eligibility must exist on the cut-off date.

Justice Sandeep Moudgil rejected the State’s stand and observed that the advertisement nowhere restricted the expression “Government” to the Government of Haryana alone. The Court held that in the absence of any explicit restriction, recognition granted by any State Government would satisfy the eligibility requirement. The Court further emphasized the settled legal principle that “rules of the game cannot be changed after the game has begun,” relying upon decisions including Maharashtra State Road Transport Corporation v. Rajendra Bhimrao Mandve, K. Manjusree v. State of Andhra Pradesh and Tej Prakash Pathak v. Rajasthan High Court.

The High Court also held that once the petitioner had been selected, appointed, and permitted to continue in service, he acquired a legitimate expectation of continuity in service. The Court clarified that although appointments may be provisional, verification cannot be used as a mechanism to retrospectively introduce new disqualifications not contained in the original advertisement.

Decision: The writ petition was allowed. The Punjab and Haryana High Court quashed the impugned termination order dated 24.07.2025 and directed the respondents to reinstate the petitioner forthwith with continuity of service and all consequential benefits.

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