PSPCL Can Reject Candidates Who Acquire Qualification After Application Deadline: Punjab & Haryana High Court Upholds Recruitment Cut-Off Date
Case Name: Manpreet Kaur v. Punjab State Power Corporation Limited
Date of Judgment: 27 May 2026
Citation: CWP-17293-2026
Bench: Justice Harpreet Singh Brar
Held: The Punjab & Haryana High Court held that candidates must possess the prescribed educational qualification on or before the cut-off date stipulated in the recruitment advertisement. The Court upheld PSPCL’s condition requiring candidates to acquire the requisite qualification by the last date of submission of applications and ruled that candidates who obtain the qualification thereafter cannot claim eligibility merely because the recruitment process or document verification is yet to take place.
Summary: The petitioner challenged Advertisement No. CRA-316/26 issued by Punjab State Power Corporation Limited (PSPCL) for recruitment to 622 posts of Junior Engineer (Electrical). She sought quashing of the eligibility condition that required candidates to possess the prescribed qualification by the last date of submission of online applications, namely 10.05.2026.
The petitioner was pursuing a Diploma in Electrical Engineering and had completed all semesters as well as mandatory industrial training. However, one examination still remained to be cleared and was scheduled to be held in June 2026, with the final result expected in July or August 2026. She argued that the qualification requirement should be assessed at a later stage, such as document verification, rather than on the application deadline.
It was further contended that the impugned condition was arbitrary and violative of Articles 14 and 16 of the Constitution because it excluded candidates who were on the verge of acquiring the qualification before completion of the recruitment process. The petitioner also sought permission to participate provisionally in the recruitment process.
Rejecting these submissions, the Court observed that the advertisement clearly permitted candidates whose results were awaited to apply only if they acquired the essential qualification by the last date of submission of applications and could produce proof thereof. The condition was unambiguous and equally applicable to all candidates.
Justice Harpreet Singh Brar held that fixation of a cut-off date serves a legitimate purpose by ensuring certainty, uniformity, transparency and finality in public recruitment. Any relaxation after commencement of the process would undermine fairness and potentially confer an undue advantage upon certain candidates.
The Court relied upon the Supreme Court’s decisions in Bhupinderpal Singh v. State of Punjab, Ashok Kumar Sharma v. Chander Shekhar, and the recent judgment in Rajasthan Public Service Commission v. Lavanshu Sankhla, reiterating the settled principle that eligibility must ordinarily be determined with reference to the date specified in the recruitment rules or advertisement. A candidate acquiring qualification after the prescribed date cannot seek consideration merely because interviews or document verification are scheduled for a later date.
The Court also emphasized that allowing candidates to acquire qualifications after the cut-off date would introduce uncertainty, create administrative difficulties, and compromise the integrity of the recruitment process.
Decision: Dismissing the writ petition, the Punjab & Haryana High Court held that the petitioner admittedly did not possess the requisite qualification on the last date prescribed for submission of applications. Since the eligibility condition contained in the advertisement was neither arbitrary nor unconstitutional, no interference was warranted under Articles 226 and 227 of the Constitution. Consequently, the petitioner was held not entitled to participate in the recruitment process for the post of Junior Engineer (Electrical) pursuant to Advertisement No. CRA-316/26.