Haryana’s Assistant Professor Recruitment Process Illegal for Violating UGC Regulations: Punjab & Haryana High Court Quashes Selection Criteria Framed by HPSC
Case Name: Asha Rani and Others v. State of Haryana and Others
Date of Judgment: 12 May 2026
Citation: CWP-661-2026 along with connected matters
Bench: Justice Tribhuvan Dahiya
Held: The Punjab and Haryana High Court held that the State of Haryana and the Haryana Public Service Commission could not modify, dilute, or selectively adopt the mandatory recruitment framework prescribed under the UGC Regulations, 2018 for appointment of Assistant Professors in Colleges. The Court ruled that Regulations 4, 5 and 6 of the UGC Regulations constitute an inseparable and composite recruitment framework governing qualifications, shortlisting, constitution of selection committees, and selection procedure, which cannot be altered by State executive instructions or recruitment criteria framed by HPSC. Consequently, the Court quashed the impugned recruitment process for Assistant Professor (English) posts conducted pursuant to Advertisement No. 48 of 2024.
Summary: The petitions challenged Advertisement Nos. 42 to 67 of 2024 issued by the Haryana Public Service Commission for recruitment to the posts of Assistant Professors in Government Colleges, along with memorandum dated 11.11.2022 issued by the State Government modifying the framework prescribed under the University Grants Commission (Minimum Qualifications for Appointment of Teachers and other Academic Staff in Universities and Colleges and Measures for the Maintenance of Standards in Higher Education) Regulations, 2018. During hearing, the challenge was confined specifically to Advertisement No. 48 of 2024 concerning Assistant Professor (English) posts.
Under the impugned recruitment process, candidates were subjected to a Screening Test followed by a Subject Knowledge Test and interview. The final merit list was prepared on the basis of marks obtained in the Subject Knowledge Test and interview. The petitioners contended that this methodology completely departed from the UGC Regulations, 2018 which mandate shortlisting on the basis of academic score criteria specified in Appendix II Table 3B, including weightage for graduation, post-graduation, NET, Ph.D., publications, teaching experience and awards, while selection itself is to be based solely on interview performance.
The State defended the recruitment process by arguing that the UGC Regulations were not automatically binding upon the State Government and had only been adopted with suitable modifications through memorandum dated 11.11.2022. It was further contended that the State possessed authority to prescribe its own procedure for recruitment in Government Colleges and that the Regulations were merely directory in nature insofar as the State Government was concerned.
Justice Tribhuvan Dahiya undertook an extensive examination of the UGC Regulations, 2018, particularly Regulations 4, 5 and 6 governing eligibility, constitution of selection committees, shortlisting criteria, and selection procedure. The Court held that these provisions collectively constitute one integrated statutory framework framed by the UGC under powers traceable to Entry 66 of List I of the Constitution dealing with coordination and determination of standards in higher education.
The High Court relied heavily upon the Supreme Court judgments in Mandeep Singh v. State of Punjab and Dr. S. Mohan v. The Secretary to the Chancellor, Puducherry Technological University. The Court observed that the Supreme Court had already recognized that UGC Regulations framed under Entry 66 List I possess overriding effect and States cannot enact or frame procedures inconsistent with such standards.
A crucial aspect emphasized by the High Court was that the State Government had selectively adopted only portions of the UGC Regulations while simultaneously introducing an entirely different selection methodology through HPSC. The Court held that once the State adopts the Regulations governing standards in higher education, it cannot segregate or remove portions relating to selection procedure and substitute them with its own modified criteria. According to the Court, qualifications, shortlisting methodology, constitution of selection committees, and selection procedure together form a single composite framework intended to maintain academic standards.
The Court specifically held that replacing the UGC-prescribed academic-score-based shortlisting mechanism with a screening examination and subject knowledge test fundamentally altered the standards prescribed by the UGC and therefore violated the constitutional scheme governing higher education standards. The impugned memorandum dated 11.11.2022 and the consequent recruitment process were accordingly found contrary to the binding UGC Regulations, 2018.
The High Court also rejected the respondents’ objection regarding delay and participation in the recruitment process by observing that candidates cannot be denied the right to challenge an illegal selection process merely because they participated in it, especially where the challenge concerns violation of mandatory statutory standards governing public recruitment.
Decision: The writ petitions were allowed to the extent challenged. The Punjab and Haryana High Court quashed Advertisement No. 48 of 2024 relating to recruitment of Assistant Professors (English) in Government Colleges and declared the modified recruitment framework adopted by Haryana through memorandum dated 11.11.2022 to be contrary to the UGC Regulations, 2018.