Punjab & Haryana High Court Rejects Intelligence Assistant Recruitment Claims; Holds B.Sc. (General) with Computer Science Not Equivalent to Prescribed Qualification

Case Name: Surinder Mohan and Another v. State of Punjab and Others
Date of Judgment: 8 January 2026

Citation: CWP-2533-2017 (O&M) and connected cases

Bench: Hon’ble Mr. Justice Kuldeep Tiwari

Held: The Punjab and Haryana High Court dismissed a batch of writ petitions challenging rejection of candidature for posts of Intelligence Assistant and Intelligence Officer in the Intelligence Wing of Punjab Police. The Court held that possession of a B.Sc. (General) degree with Computer Science as one of the subjects does not satisfy the prescribed educational qualification of either an ‘O’ Level Certificate from DOEACC/NIELIT or a degree specifically in Computer Science or allied disciplines as stipulated in the recruitment advertisements. The Court further held that equivalence of qualifications is a technical academic matter within the exclusive domain of the recruiting authority and cannot be determined through judicial review.

Summary: The petitioners had applied pursuant to Advertisement Nos. 1 of 2016 and 2 of 2016 for direct recruitment to the posts of Intelligence Assistant (Constable rank) and Intelligence Officer (Sub-Inspector rank) in the Intelligence Wing of Punjab Police. Although the petitioners cleared the physical efficiency test and written examination, their candidature was rejected at the stage of document verification on the ground that they did not possess the requisite educational qualifications.

The core dispute revolved around the interpretation of prescribed qualifications, which required either a graduate degree along with an ‘O’ Level Certificate in Information Technology from DOEACC/NIELIT or a degree such as B.Sc./B.Tech./B.E. in Computer Science, Information Technology, Information Systems, BCA, or PGDCA. The petitioners contended that they held B.Sc. degrees with Computer Science as a subject and that such qualification was higher than the ‘O’ Level Certificate. They relied on university prospectuses, fee receipts, and clarifications issued by universities to claim equivalence with B.Sc. (Computer Science).

The State opposed the petitions, asserting that the recruitment was conducted strictly in accordance with the Punjab Intelligence Cadre (Group ‘C’) Service Rules, 2015 as amended in 2016, and that a Committee of Experts comprising university representatives had concluded that B.Sc. (General) with Computer Science as one subject is not equivalent to B.Sc. (Computer Science). It was further contended that the issue of equivalence had already been conclusively settled by earlier decisions of the High Court, including dismissal of similar writ petitions and affirmation thereof in Letters Patent Appeals.

The High Court noted that identical claims had been rejected in CWP-13-2017 and LPA-1453-2019, which had attained finality. Relying on binding Supreme Court precedents, including Zahoor Ahmad Rather, Unnikrishnan C.V., Yogesh Kumar, and Shifana P.S., the Court reiterated that higher qualification does not automatically imply eligibility unless it is in the same line and discipline, and that courts cannot expand or dilute recruitment criteria by determining equivalence.

The Court further held that fresh or corrected degrees issued to some petitioners during pendency of the writ petitions could not be taken into account, as eligibility has to be assessed with reference to qualifications held at the time of recruitment. The concluded selection process of 2016–2017 could not be reopened in the absence of arbitrariness or mala fides.

Decision: All the writ petitions were dismissed. The Court upheld the rejection of the petitioners’ candidature and held that they were not eligible for appointment to the advertised posts.