Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2025 Supreme(Online)(P&H) 9608

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Sandeep Moudgil, J
Naveen – Appellant
Versus
State of Haryana – Respondent
CWP-29861-2025

Advocates:
For the Appellants/Petitioners: Sanchit Punia
For the Respondents: Rahul Dev Singh

A candidate cannot claim rights to a Sports Gradation Certificate unless their achievements map to the specific categories defined in the prevailing government sports policy; parity with prior recruitment cycles is inapplicable when policies have been modified by subsequent notifications.

Headnote:(A) Constitution of India - Article 226 - Writ jurisdiction - Quashing of order rejecting Sports Gradation Certificate - Petitioner sought appointment to Group D post under Eligible Sports Person category - Claim rejected on grounds that petitioner's sports achievement was not covered under the prevailing Policy dated 15.11.2018. (Paras 1, 9, 15)

(B) Sports Policy - Sports Gradation Certificate - Eligibility - Policy dated 25.05.2018 modified by notification dated 15.11.2018 supersedes previous instructions - Achievement must be mapped to specific categories for gradation - Court held that Department is bound to act strictly in accordance with notifications. (Paras 8, 16, 20)

(C) Equality - Article 14 and 16 - Claim of discrimination - Petitioner claimed parity with other candidates - State explained that certificates issued to others were based on previous recruitment cycles and distinct court directions - Held, no discrimination as petitioner's case is governed by a later policy that does not recognize his specific event. (Paras 10, 19, 21)

Facts of the case:
The petitioner, an aspirant for a Group D post under the BC

(B) Eligible Sports Person category, challenged the rejection of his request for a Sports Gradation Certificate. The petitioner contended that his participation in the 53rd Haryana State School Tournament in Netball entitled him to the certificate, citing previous court rulings and instances of other candidates receiving the same. The State argued that the current policy of November 2018 does not include the petitioner's specific event in the gradable categories, and no certificate could be issued.

Findings of Court:
The court observed that the Department's role is restricted to grading achievements strictly according to the prevailing notified policy. It found that the petitioner's event did not qualify for gradation under the amended policy, and he failed to utilize opportunities to amend his category status during the recruitment process. The petition for parity with candidates from different recruitment periods was rejected.

Issues: Whether the rejection of the Sports Gradation Certificate was arbitrary or discriminatory under Articles 14 and 16, and whether the respondent is bound to issue such a certificate for an achievement outside the specified policy categories.

Ratio Decidendi: Government authorities are bound by the strict wording of prevailing sports policies; where an achievement is not mapped to a gradation category under the applicable policy, no mandamus can be issued to grant a certificate, and parity cannot be claimed based on certificates issued under different, earlier regulatory frameworks.

Result: Writ petition dismissed.

Table of Content
1. jurisdiction and factual background of the sports quota claim. (Para 1 , 1 , 2 , 3 , 4)
2. petitioner's contentions regarding article 14 and past precedents. (Para 5 , 6 , 7)
3. respondent's defense based on policy adherence and estoppel. (Para 8 , 9 , 10 , 11 , 12 , 13)
4. court's analysis of policy applicability and final order. (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23)

(1). The jurisdiction of this Court has been invoked under Article 226 of the Constitution of India, inter alia, for issuing a writ of certiorari quashing the letter dated 09.05.2025 (Annexure P11) whereby respondent No.3 rejected the case of the petitioner for issuance of Sport Gradation Certificate. He seeks a direction to the respondents to issue Sport Gradation Certificate to the petitioner and to grant him appointment to a Group ‘D’ post against Advertisement No.1/2023 dated 30.05.2023 under BC(B) Eligible Sports Person category and to keep one such post vacant during to the pendency of the writ petition.

Facts.

(2). The Haryana Staff Selection Commission (in short, the HSSC), Panchkula, advertised 13,536 Group D posts across various state departments on 30.05.2023 (Annexure P1). The petitioner is stated to be a qualified and eligible candidate, applied for the same under the Eligible Sports Persons (ESP) category in BCB quota for the Common Eligibility Test (CET) (Annexures P2 & P3). Having participated as a Netball player in the District School Tournament, Rewari, and the 53rd Haryana State Schools Tournament (Boys/Girls) before the cut-off date, the petitioner uploaded these achievement certificates, making him eligible for consideration under the prevalent sports policy of the Haryana Govt.

(3). The HSSC declared CET results on 12.01.2024, where the petitioner scored 44.4915342 marks i.e. above the BCB ESP cut-off of 39.35 and as such, he was qualified (Annexure P4). Upon approaching the HSSC for the next selection stage, he was asked to submit a Sports Gradation Certificate as per policies dated 25.05.2018 or 15.11.2018 (Annexures P5 & P6). The petitioner applied to the District Sports and Youth Affairs Officer, submitting his certificates, but on 09.05.2025 (Annexures P11), his request was rejected despite similar certificates being approved for others such candidates.

(4). Hence, this writ petition.

Petitioner’ Contention

(5). Learned counsel for the petitioner contends that the impugned rejection letter dated 09.05.2025 (Annexure P11) issued by the respondent District Sports and Youth Affairs Officer is wholly illegal, arbitrary, discriminatory, and violative of Articles 14 and 16 of the Constitution of India in view of the fact that the petitioner, a male Netball player, indisputably participated in the District School Tournament, Rewari, and the 53rd Haryana State Schools Tournament well before the cut-off date stipulated under the Sports Policy Notification dated 25.05.2018, and possesses valid certificates proving the same, however, despite submitting these documents, his application for issuance of Sports Gradation Certificate was rejected in a patently unreasoned manner, even though candidates with identical or similar sports achievements have routinely been granted such certificates by the same authority as is evident from the list (Annexure P-12) vide which the respondents have issued Sports Gradation Certificate for the same event.

(6). Reliance has been placed on the judgment dated 14.12.2018 passed in CWP Nos. 4182 of 2018 ( Brij Pal vs. State of Haryana ) (Annexure P-14) whereby this Court categorically held that participation in qualifying tournaments before the cut-off date regardless of the subsequent date of certificate issuance, entitles candidates to participate under the Outstanding/Eligible Sports Persons category and said judgment was affirmed by the Division Bench of this Court in LPA No.1391 of 2019 (State of Haryana & Anr. vs. Brij Pal) decided on 13.09.2019 and he

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2025 Supreme(Online)(P&H) 9608

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARHSandeep Moudgil, JNaveen – AppellantVersusState of Haryana – RespondentCWP-29861-2025

A candidate cannot claim rights to a Sports Gradation Certificate unless their achievements map to the specific categories defined in the prevailing government sports policy; parity with prior recruitment cycles is inapplicable when policies have been modified by subsequent notifications.

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Sandeep Moudgil, J
Naveen – Appellant
Versus
State of Haryana – Respondent
CWP-29861-2025