Punjab & Haryana High Court Upholds HPSC Screening Test Pattern for Assistant Environmental Engineer Posts; Says Engineering Subjects’ Exclusion Not Arbitrary
Case Name: Amit Ahalawat v. State of Haryana & Others
Date of Judgment: October 31, 2025
Citation: CWP-32117-2025
Bench: Hon’ble Mr. Justice Harpreet Singh Brar
Held: The Punjab & Haryana High Court dismissed a writ petition challenging the Haryana Public Service Commission’s (HPSC) revised screening test scheme for recruitment of Assistant Environmental Engineers in the Haryana State Pollution Control Board (HSPCB). Justice Harpreet Singh Brar held that prescribing a general knowledge–based screening test, instead of engineering subjects, did not violate Articles 14 or 16 of the Constitution. The Court observed that the screening stage only serves to shortlist candidates and does not contribute to the final merit, and that it is within the prerogative of the Commission as an expert body to determine the syllabus and evaluation criteria. The Court cited Maharashtra Public Service Commission v. Sandeep Shriram Warade (2019) 6 SCC 362 and Satya Dev Bhagaur v. State of Rajasthan (2022) 5 SCC 314 to emphasize judicial restraint in policy matters unless the decision is palpably arbitrary.
Summary: The petitioner, possessing degrees in Civil Engineering, challenged the 2025 HPSC announcement for the Assistant Environmental Engineer recruitment, arguing that the exclusion of technical subjects in the screening test was irrational and had no nexus with the advertised post. He contended that the earlier 2023 recruitment cycle included engineering topics, giving him a legitimate expectation of a similar syllabus. The HPSC defended its decision, explaining that over half the previous posts remained vacant due to the complexity of the syllabus and that simplifying the screening test was aimed at expediting recruitment. The Court noted that all candidates possessed similar qualifications, the screening stage required only 25% qualifying marks, and the marks were not counted toward final selection. Relying on precedents including Ashish Kumar v. State of Haryana (CWP-24605-2025), the Court reiterated that courts cannot substitute their views for those of expert bodies in academic or recruitment matters unless illegality, mala fides, or arbitrariness is proven.
Decision: The High Court dismissed the petition, upholding the validity of the HPSC screening test syllabus. It ruled that the revised pattern was neither discriminatory nor arbitrary and that determining examination content lies within the Commission’s expert discretion. Pending miscellaneous applications were also disposed of.