Relaxation at Screening Stage Bars Migration: P&H High Court Upholds BC-B Candidate’s Non-Migration to General Category
Case Name: Kartik Saini v. State of Haryana and Others
Date of Judgment: 17 February 2026
Citation: CWP-38944-2025
Bench: Hon’ble Mr. Justice Harpreet Singh Brar
Held: The Punjab and Haryana High Court held that a reserved category candidate who avails relaxation at any stage of the selection process, including at the preliminary/screening stage, cannot subsequently claim migration to the General category on the basis of higher marks in later stages. Relaxation at the screening stage constitutes a tangible advantage and disentitles such candidate from being treated as selected on general standards.
Summary: The petitioner challenged the final result dated 15.12.2025 for the post of Assistant Environmental Engineer (Group-B) in Haryana Pollution Control Board pursuant to Advertisement No.20/2025, seeking inclusion of his name in the list of selected candidates .
The selection process comprised three stages: Screening Test, Subject Knowledge Test and Interview. The petitioner, a BC-B category candidate, qualified all stages but was not selected in the final result .
The grievance of the petitioner was that one Nikhil Yadav, also a BC-B candidate, secured 58.86 marks in the final merit, which was higher than the last selected General category candidate who secured 53.09 marks. It was argued that Nikhil Yadav ought to have been migrated to the General category and, upon such migration, the petitioner would have been selected against the BC-B vacancy .
The respondents opposed the petition, pointing out that Nikhil Yadav had secured 56.86 marks in the Screening Test, whereas the General category cut-off was 61.8132. He was shortlisted for the Subject Knowledge Test only by availing relaxed standards applicable to BC-B category candidates .
The Court framed the principal issue as whether a reserved category candidate who has availed relaxation at the Screening Test stage can be migrated to the General category on the basis of subsequent performance .
After examining the record, the Court held that a screening test functions as a mandatory eligibility sieve. Relaxation granted at that stage confers a decisive advantage, as without such relaxation the candidate would not have progressed further in the selection process .
Relying extensively upon the judgment of the Hon’ble Supreme Court in Union of India v. G. Kiran & Ors. (decided on 06.01.2026), the Court held that availing relaxation at any stage of examination disentitles a reserved category candidate from being adjusted against unreserved vacancies . The Court also referred to Niravkumar Dilipbhai Makwana v. Gujarat Public Service Commission and Gaurav Pradhan v. State of Rajasthan, reiterating that once relaxation is availed, migration is impermissible .
The Court distinguished the reliance placed on Saurav Yadav v. State of U.P., observing that the principle of migration applies only where a candidate has not availed any relaxation at any stage of the process .
Further, Clause 16(ix) of Advertisement No.20/2025 clearly stipulated that when a relaxed standard is applied in selection of a BC-B candidate, such candidate shall be counted against reserved vacancies and deemed unavailable for consideration against unreserved vacancies . The Court held that the advertisement has the force of law and binds the parties.
The Court also observed that the petitioner participated in the entire selection process without protest and approached the Court only after being declared unsuccessful. A candidate who participates without challenge cannot subsequently assail the process .
Concluding that Nikhil Yadav had availed relaxation at the screening stage and was therefore rightly treated as a BC-B candidate throughout, the Court held that no case for interference was made out .
Decision: The writ petition was dismissed.