Punjab & Haryana High Court Upholds ITI-Only Eligibility for ALM Recruitment; Holds Higher Engineering Degrees Do Not Create Automatic Equivalence
Case Name: Sanjay Kumar and Others v. Punjab State Transmission Corporation Limited
Date of Judgment: 22 January 2026
Citation: CWP-10347-2021
Bench: Hon’ble Mr. Justice Harpreet Singh Brar
Held: The Punjab and Haryana High Court dismissed the batch of writ petitions and upheld the recruitment advertisement issued by Punjab State Transmission Corporation Limited (PSTCL), holding that candidates possessing diploma or degree qualifications in Electrical Engineering cannot claim equivalence with the prescribed ITI qualification unless such equivalence is expressly provided by service rules or the recruitment advertisement. The Court held that courts cannot rewrite eligibility conditions or declare equivalence of qualifications in exercise of judicial review under Article 226.
Summary: The petitioners challenged Advertisement No. CRA-11/2021 dated 18.05.2021 issued by PSTCL for recruitment to 350 posts of Assistant Lineman (ALM) and 150 posts of Assistant Sub-Station Attendant (ASSA). The essential qualification prescribed was Matriculation with Punjabi and a full-time regular ITI certificate in Electrician/Wireman trade from a recognised institution.
The petitioners, who possessed diploma or degree qualifications in Electrical Engineering, contended that possession of a higher qualification in the same field necessarily presupposes acquisition of the lower qualification, and therefore exclusion of degree/diploma holders was arbitrary and violative of Articles 14 and 16 of the Constitution. Reliance was placed on decisions such as Jyoti K.K. v. Kerala PSC and Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad.
PSTCL opposed the petitions, submitting that eligibility criteria were unambiguous, that no equivalence clause existed, and that the employer is the best judge of suitability and job requirements. It was argued that courts cannot compel employers to treat higher academic qualifications as equivalent to vocational qualifications designed for hands-on technical roles.
The High Court undertook an extensive survey of Supreme Court jurisprudence on equivalence of qualifications and judicial review in recruitment matters, including Zahoor Ahmad Rather, Maharashtra PSC v. Sandeep Shriram Warade, Devender Bhaskar v. State of Haryana, and Ganpat Singh Gangaram Singh Rajput v. Gulbarga University. The Court reiterated that equivalence of qualifications is a technical and academic matter within the exclusive domain of the employer or rule-making authority.
The Court distinguished earlier cases relied upon by the petitioners by noting that in those matters, either service rules expressly provided for equivalence or specific government notifications extended eligibility to higher-qualified candidates. No such notification or policy was shown to exist for PSTCL or the State of Punjab.
It was further held that vocational ITI training and engineering degrees serve distinct purposes, and it cannot be assumed that a degree holder necessarily possesses the trade-specific practical skills imparted through an ITI course. The Court rejected the plea of discrimination, holding that classification based on job-oriented qualifications had a rational nexus with the object sought to be achieved.
Decision: All the writ petitions were dismissed. The Punjab and Haryana High Court upheld the validity of Advertisement No. CRA-11/2021 and held that PSTCL was justified in restricting eligibility to candidates possessing the prescribed ITI qualification. No relief was granted to diploma or degree holders in Electrical Engineering.