Courts Cannot Assess Examination Difficulty Levels: Punjab and Haryana High Court's Landmark Ruling
The Punjab and Haryana High Court has delivered a significant judgment clarifying the boundaries of judicial intervention in recruitment processes, specifically dismissing a plea from candidates of the 2016 constable recruitment examination. The court emphatically stated that it possesses no mechanism to determine whether examination questions meet specific educational standards, such as 10+2 or graduation levels, nor can it interfere with the discretionary marking practices of selection boards.
Judicial Review Boundaries in Recruitment Processes
Justice Jagmohan Bansal, presiding over the case, highlighted that setting examination papers remains the exclusive prerogative of recruitment authorities. The court can only intervene when there is concrete evidence of mala fide intentions, misuse of power, or abuse of process. In the absence of such evidence, judicial review cannot extend to questioning the authenticity or validity of marks awarded during interviews, personality tests, or physical measurement tests.
The petitioners, who were disqualified following the court's earlier order on their plea, argued that the Haryana Staff Selection Commission had asked questions at a graduation level despite public notices specifying a 10+2 standard. However, the court maintained that determining the standard of questions falls squarely within the recruitment board's domain, and courts lack the necessary yardstick to assess such academic matters.
Key Findings and Rationale Behind the Dismissal
The court's order outlined several critical findings:
- Time Lapse Considerations: The selection process commenced in 2015 and concluded in 2017, with over eight years having passed since completion. For a physically demanding role like constable, maintaining the required fitness levels over such an extended period becomes impractical.
- Fitness Paramount for Police Roles: Physical and mental fitness are of paramount importance in police forces. Candidates cannot be expected to retain the same fitness levels required at the initial selection stage after such a significant time gap.
- Discretionary Marking Authority: The recruitment board's authority to award marks in interviews and physical tests remains unchallengeable unless arbitrariness or mala fide is proven.
Background of the Recruitment Dispute
The controversy originated from a 2015 advertisement for constable positions, which outlined a four-stage selection process:
- Physical Screening Test (PST)
- Knowledge Test
- Physical Measurement Test (PMT)
- Interview-cum-Personality Test
The petitioners were initially declared unsuccessful in the PST conducted in mid-2016. Following their disqualification, they approached the High Court with various pleas, claiming they had actually qualified but were wrongly declared unsuccessful. Although the state reconsidered their case as a "special case" in 2017, allowing them to sit for a written knowledge test, their names did not appear in the final results declared on June 23, 2017, leading to the current legal challenge.
Court's Directive for Future Scrutiny
While dismissing the plea, the court noted that eight other candidates who fought the case were permitted to participate in a special knowledge test and were ultimately selected, while all petitioners were rejected. This discrepancy suggested possible undue favoritism toward those eight candidates. Since these candidates were unrepresented in court, no adverse order could be passed against them directly.
The court appropriately directed the Director General of Police, Haryana, and the Chairman of the Haryana Staff Selection Commission to examine the matter thoroughly and take appropriate action where necessary, ensuring transparency and fairness in future recruitment processes.
This ruling reinforces the principle that while courts serve as guardians against arbitrariness and malpractices, they must respect the specialized domains of recruitment boards and academic evaluation standards, maintaining a balanced approach to judicial review in administrative matters.
