Transitional Rule Protecting Eligibility Also Saves Pre-B.Ed. Teaching Experience: Punjab & Haryana High Court Directs Recalculation of PGT Mathematics Merit and Creation of Supernumerary Post if No Vacancy Exists
Case Name: Ranpal Singh Panwar v. State of Haryana and Others
Date of Judgment: 22 September 2026
Citation: CWP-20028-2023
Bench: Hon’ble Mr. Justice Harpreet Singh Brar.
Held: The Punjab and Haryana High Court held that where a transitional provision expressly preserves the eligibility of candidates governed by the earlier service rules, teaching experience validly acquired under those earlier rules cannot subsequently be ignored merely because an additional qualification was introduced by an amendment.
The Court found that under the Haryana State Education Lecturer School Cadre (Group C) Service Rules, 1998, the post then designated as Lecturer (Mathematics) required a postgraduate qualification in Mathematics with the prescribed marks, whereas the 2012 Rules subsequently redesignated the post as PGT Mathematics and introduced B.Ed. as an additional essential qualification.
However, Rule 19-A was inserted as a transitional measure specifically to protect persons who were eligible under the 1998 Rules. It permitted such candidates to remain eligible for recruitment as a one-time measure, provided they acquired HTET and B.Ed. within the stipulated period. The petitioner had obtained his B.Ed. on 09.07.2014, within the period permitted by the transitional provision.
The Court consequently held that once the petitioner’s eligibility under the earlier rules had been expressly saved, the teaching experience acquired while he was validly qualified under those rules could not be retrospectively wiped out. To hold otherwise would make the transitional protection meaningless. The amended criterion requiring experience to be counted after acquisition of the newly introduced qualification had to operate prospectively and could not be used to exclude experience already accrued before the amendment.
Summary: The petitioner, Ranpal Singh Panwar, participated in the selection process initiated by the Haryana authorities for recruitment to the post of PGT Mathematics under Advertisement No. 4/2015. He applied in the General Category and challenged various final results insofar as he was awarded fewer marks for teaching experience than what, according to him, his service record entitled him to receive. He sought a direction for grant of additional experience marks and consequential appointment on the ground that his revised merit would place him above the last selected General Category candidate.
The petitioner relied upon experience certificates showing that he had served as a School Lecturer over a substantial period and contended that the breaks reflected in service were attributable only to summer vacations. His case was that he possessed more than three years of eligible experience but had not received the full marks attributable to that period.
The dispute turned principally on the change in statutory qualifications between the 1998 Rules and the 2012 Rules. Under the earlier rules, the essential qualification for Lecturer Mathematics was a postgraduate degree in the relevant subject with at least 50% marks, whereas the later rules required, in addition, a B.Ed. degree and prescribed other eligibility requirements. The post itself was redesignated from Lecturer to Post Graduate Teacher.
Recognising that existing teachers could suffer hardship because of the sudden introduction of new qualifications, the State inserted Rule 19-A through the 2012 amendment. The transitional provision allowed persons who fulfilled the qualifications prescribed under the 1998 Rules to remain eligible for recruitment as a one-time measure, subject to acquisition of HTET and B.Ed. within the specified period.
The advertisement separately provided that teaching experience would ordinarily be considered only after acquisition of the essential qualification and had to be duly certified by the competent education authority. At the same time, the advertisement itself relaxed the timing requirement relating to HTET by permitting candidates who passed HTET up to the date of interview to participate. The petitioner qualified HTET on 25.07.2016, before his interview on 09.11.2016, and the respondents did not dispute his eligibility on that account. The controversy was therefore confined to the manner in which his prior teaching experience was to be counted.
The High Court held that the petitioner’s experience had to be examined in the context of the statutory transitional protection. Since he possessed the qualification prescribed under the 1998 Rules and obtained his B.Ed. within the time permitted under Rule 19-A, the experience lawfully earned before introduction of the B.Ed. requirement remained valid. A contrary interpretation would defeat the very object of the transitional provision by recognising earlier eligibility in theory while nullifying the experience acquired on the strength of that eligibility.
Decision: The writ petition was allowed. The High Court directed the respondents to treat the petitioner’s teaching experience as valid and award him the requisite marks for more than three years of experience. After adding the appropriate experience marks, the authorities were directed to re-determine his merit and, if his revised score exceeded that of the last selected candidate in the General Category, to consider him for appointment to the post of PGT Mathematics.
Significantly, the Court protected the appointments of candidates already selected and working. It directed that they would not be disturbed and further ordered that, if no regular vacancy was available, a supernumerary post was to be created for the petitioner. He was also held entitled to notional benefits from the date his batch-mates joined, though actual salary would be payable only from the date of his actual joining.