Candidate Can’t Change Reserved Category After Results: Punjab & Haryana High Court Upholds Finality of Recruitment Forms Despite ‘Clerical Error’ Plea

Case Name: Parwinder Singh v. State of Punjab and Others

Date of Judgment: 06 May 2026

Citation: CWP-13909-2026

Bench: Justice Harpreet Singh Brar

Held: The Punjab and Haryana High Court held that a candidate who consciously selects a particular reserved category while filling an online recruitment form and participates in the entire selection process cannot later seek alteration of the category after declaration of results on the ground of a clerical or inadvertent mistake. The Court ruled that explicit recruitment conditions prohibiting change of category after submission of the application form are binding and cannot be diluted on equitable considerations.

Summary: The petitioner applied for the post of Telephone Mechanic pursuant to Advertisement CRA No.12/2025 issued by Punjab State Transmission Corporation Limited (PSTCL). While submitting the online application form, the petitioner selected the Scheduled Caste (R&O) sub-category instead of his actual sub-category, namely Scheduled Caste (Mazhabi & Balmiki) [SC (M&B)]. According to the petitioner, the error was purely bona fide and inadvertent.

The petitioner possessed a valid SC (M&B) certificate issued prior to the cut-off date and claimed that had he been considered in the correct sub-category, he would have comfortably fallen within the zone of selection. After declaration of the result, the petitioner submitted representations and also approached the High Court earlier seeking consideration under the correct category. However, the competent authority rejected his claim through a speaking order dated 15.04.2026, which became the subject matter of challenge in the present writ petition.

The petitioner relied upon earlier High Court decisions including Usha Dhillon v. State of Haryana and Asha Devi v. Haryana Staff Selection Commission to argue that procedural technicalities should not defeat substantive rights where the candidate possessed the requisite certificate before the cut-off date and the mistake was genuinely inadvertent.

Opposing the petition, the State and recruiting authority contended that the recruitment advertisement expressly provided that once a category or sub-category was selected in the online form, the same could not be altered under any circumstances after submission. It was further argued that the petitioner had consciously participated in the entire recruitment process under the SC (R&O) category and only sought correction after declaration of the result, which would unsettle the selection process and prejudice other candidates.

Justice Harpreet Singh Brar examined the recruitment conditions and noted that the advertisement contained clear and unambiguous stipulations declaring the category exercised in the application form to be final. The Court observed that such clauses formed an essential condition of participation in the recruitment process and left no scope for alteration after submission of the form.

Relying upon Rajasthan High Court, Jodhpur v. Neetu Harsh and J&K Public Service Commission v. Israr Ahmed, the Court reiterated the settled principle that once a candidate consciously exercises an option regarding category and participates in the selection process on that basis, the candidate cannot later resile from the declared position to seek a more beneficial category.

The High Court distinguished the judgments relied upon by the petitioner by observing that in those cases corrections were sought at an early or pre-decisional stage, whereas in the present matter the request was made after declaration of results. The Court emphasized that entertaining such claims at a belated stage would open floodgates of litigation and undermine the sanctity and certainty of public recruitment processes.

Decision: The writ petition was dismissed. The Punjab and Haryana High Court upheld the speaking order rejecting the petitioner’s request for change of sub-category from SC (R&O) to SC (M&B) after declaration of results.