Punjab & Haryana High Court Quashes HPSC Screening Test Pattern for Assistant District Attorney Posts — Holds Exclusion of Legal Subjects Arbitrary and Unconstitutional

Case Name: Lakhan Singh v. State of Haryana & Others (and connected matters).
Date of Judgment: October 17, 2025
Citation: CWP-25672-2025 (and connected matters)
Bench: Hon’ble Mr. Justice Sandeep Moudgil

Held: The Punjab & Haryana High Court set aside the Haryana Public Service Commission’s (HPSC) scheme for recruitment to the post of Assistant District Attorney (ADA) under Advertisement No. 18/2025, holding that the exclusion of legal subjects from the screening-test syllabus was arbitrary, irrational, and violative of Articles 14 and 16 of the Constitution.

Justice Sandeep Moudgil ruled that a screening test for a legally specialized post cannot be based solely on general knowledge and reasoning, as it bears no rational nexus to the post’s core functions. The Court reiterated that public employment is a constitutional right demanding fairness, transparency, and statutory compliance, including adherence to Article 320(3)(b) of the Constitution and Clauses 41–42 of the Haryana Public Service Commission (Limitation of Functions) Regulations, 1973.

Summary: The batch of writ petitions was filed by multiple aspirants challenging the HPSC announcement dated August 8, 2025, which introduced a general-knowledge-based screening test for the ADA post—completely excluding law subjects from the first stage of recruitment. Petitioners contended that this abrupt departure from earlier exam patterns (where 80 % weightage was for law) violated legitimate expectations and deprived law graduates of a fair opportunity.

The Commission defended its decision citing administrative convenience and its discretion under Clause 10 of the advertisement to determine the selection process. It argued that legal proficiency would be tested later in the Subject Knowledge Test and Interview.

After analyzing constitutional provisions, precedents including Mandeep Singh v. State of Punjab (2025 INSC 834) and Lila Dhar v. State of Rajasthan (1981 4 SCC 159), and principles of judicial review, the Court found:

• The screening test lacked a rational nexus with the legal qualifications required for the post.
• Eliminating law subjects undermined the purpose of professional legal education and operated as an arbitrary filter eliminating over 85 % of candidates before their legal competence could be tested.
• The Commission’s failure to consult the State Government before altering the syllabus violated Clause 41–42 of the 1973 Regulations and Article 320(3)(b).
• Administrative convenience cannot justify discriminatory or unconstitutional recruitment practices.

Justice Moudgil observed that “opportunity cannot be a mirage; it must be real, accessible, and meaningful,” underscoring that fairness and merit must guide all public employment.

Decision: Allowing all connected writ petitions, the High Court quashed the HPSC announcement dated 08.08.2025 prescribing the impugned screening-test pattern. It directed the Commission to reformulate the examination scheme and syllabus in line with constitutional principles, ensuring the inclusion of legal subjects at the initial stage to evaluate candidates’ professional competence.

Justice Moudgil concluded that recruitment to public service “is not a mechanical sieve that shuts out merit for the sake of convenience” and reaffirmed that the State, as a model employer, must act with fairness, reason, and equity in all its actions.