‘Assessing Only Theoretical Knowledge Fails To Reflect Skills For Public Administration’: Punjab & Haryana High Court Dismisses Plea Against HPSC Screening Test
Safiya Malik
The High Court of Punjab and Haryana, Single Bench of Justice Harpreet Singh Brar dismissed a petition contesting the Haryana Public Service Commission’s screening test scheme for the post of Assistant Environmental Engineer in the Haryana State Pollution Control Board. The Court observed that recruitment processes for government posts must progress beyond role learning and mechanical recall, as assessing only theoretical knowledge fails to reflect the skills essential for effective public administration. Upholding the inclusion of general awareness, general knowledge, and mental ability components in the screening test, the Bench held that such areas of assessment are justifiable for evaluating candidates’ overall aptitude and that framing the syllabus lies within the Commission’s discretion, warranting no judicial interference.
The petitioner, holding Bachelor’s and Master’s degrees in Civil Engineering, applied for the post of Assistant Environmental Engineer in the Haryana State Pollution Control Board pursuant to Advertisement No.20/2025 dated 13.08.2025. The Haryana Public Service Commission structured the recruitment process into three stages: screening test, subject knowledge test, and interview. The petitioner challenged the announcement dated 13.08.2025 prescribing the scheme and syllabus for the screening test, asserting that the syllabus excluded engineering-related subjects and lacked rational nexus with the technical nature of the post. He asserted a legitimate expectation based on the 2023 advertisement, where the screening test had included engineering-related topics.
The petitioner relied on a previous judgment in Lakhan Singh v. State of Haryana. In response, HPSC stated that during the 2023 recruitment cycle, 7189 applications were received against 54 posts, but only 25 candidates were found suitable, leaving 29 posts vacant. Therefore, the Commission revised the screening test syllabus by including general topics to simplify the procedure. It was further submitted that candidates were only required to secure 25% marks in the screening test, and the marks from the screening test would not be added to the final result. HPSC also pointed out that the petitioner had raised no prior grievance and filed the writ petition after admit cards had been issued to 3637 candidates.
HPSC relied on the Division Bench decision in Ashish Kumar v. State of Haryana, where it was held that the Commission, being an expert body, is competent to decide the subjects for shortlisting. It was also submitted that the Supreme Court had refused to interfere with similar policies in SLP(C) Nos.18363/2024 and 21347–21348/2024. The petitioner contended violation of Articles 14 and 16 of the Constitution, while the respondents maintained that general knowledge and analytical abilities were relevant for public service roles.
Justice Harpreet Singh Brar observed that the recruitment process for government employment must move beyond traditional patterns of rote learning. The Court recorded that “the general trend in recruitment to government jobs continues to rely heavily on bookish knowledge. The examinations conducted for this purpose tend to emphasize upon rote learning and the mechanical reiteration of facts rather than assessing critical thinking or practical problem-solving abilities.”
The Bench further stated that “such an approach often fails to account for creativity, adaptability, emotional intelligence and other such skills that are essential for effective administration, especially in the context of public service.” The judgment welcomed recruitment methods that test a candidate’s overall aptitude, noting that “it is certainly a welcome step when the authorities responsible for recruitment look beyond the traditional norms and adopt a process that attempts to gauge a candidate’s overall intelligence quotient and situational judgment.”
The Court held that “as far as the integration of general awareness into the selection criterion is concerned, this Court is of the considered opinion that the same cannot be considered irrelevant especially for posts that require interdisciplinary considerations.” The Bench reasoned that “it is entirely justifiable to expect future public servants to have cognitive alertness, practical decision making capacity with a constitutional sensibility and a sense of civic awareness.”
The Court stated that “the very nature of the job demands that the officers are aware of scientific advancements, socio-economic trends and public policy developments to serve the people to the best of their abilities.” It added that “general knowledge exams go beyond testing memory and delve into the field of analytical comprehension ensuring that the candidate can identify issues, connect diverse subjects, predict consequences and make informed decisions.”
The Bench observed that “it is the prerogative of the employer to lay down an eligibility criterion as it alone can best judge suitability of a candidate for the advertised role.” Citing precedent, the Court reiterated that “Courts must not interfere in recruitment process when the advertisement qua the same is clear and within the legal framework.”
The Court stated that “this Court finds no merit in the submissions advanced by learned counsel for the petitioner. The impugned action of the respondent-HPSC does not suffer from any legal infirmity warranting interference under Articles 226/227 of the Constitution of India.”
“The writ petition is dismissed. Pending miscellaneous application(s), if any, shall also stand disposed of.”
Advocates Representing the Parties
For the Petitioner: Mr. A.S. Nirmaan, Advocate
For the Respondents:
Mr. Kanwal Goyal, Advocate for respondent No.2–HPSC
Ms. Mansi, Advocate for Mr. Sukhdeep S. Parmar, Advocate for respondent No.3–HSPCB
Case Title: Amit Ahalawat v. State of Haryana and others
Neutral Citation: 2025: PHHC:149766
Case Number: CWP-32117-2025 (O&M)
Bench: Justice Harpreet Singh Brar
