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2026 Supreme(Online)(P&H) 79053
IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH
Jasgurpreet Singh Puri, Amarjot Bhatti, JJ
Karanbir Singh Deyea – Appellant
Versus
State of Punjab – Respondent
LPA-48-2026
For the Appellants/Petitioners: Sanjeev Sharma, Vikram Vir Sharda, Sandeep Singh
For the Respondents: Anu Chatrath, Raghav Goel
An applicant for a specialized public post must meet the essential educational qualifications strictly as prescribed in the recruitment advertisement, and in the absence of procedural illegality, the court will not interfere with selection criteria or the application of a reservation roster based on combined merit.
Headnote:(A) Police Recruitment - Sub Inspectors in Technical and Support Services (TSS) Cadre - Eligibility - Educational Qualification - Requirement of 1-year diploma/course in Open Source Intelligence (OSINT) or related platforms - Appellant possessed Diploma in Computer Applications but failed to meet specific OSINT technical course criteria mandated by advertisement - Held, applicant must possess strictly defined essential qualification; courts cannot dilute clear advertisement stipulations. (Para 8)
(B) Appellate Review - Selection Roster - Reservation policy applied on combined merit list rather than domain-wise - No waiting list provision - Held, in absence of challenge to advertisement terms, court will not interfere with recruitment process conducted per published guidelines. (Paras 9, 10)
Facts of the case:
Appellant participated in the selection process for the post of Sub Inspector (TSS Cadre) under the OSINT specialization category. While clearing technical phases, he was disqualified during document verification for lacking the mandatory one-year specialized diploma in OSINT. His subsequent writ petition was dismissed by a Single Judge, and he appealed to this court.
Findings of Court:
The court observed that the educational criteria were explicit and the appellant’s basic Computer Applications certificate did not fulfill the OSINT technical subject requirements. The recruitment process strictly followed the published reservation roster on a combined merit basis, and as the appellant failed to meet the essential qualification, his non-selection was justified.
Issues: Whether the appellant possessed the essential technical educational qualification mandated by the advertisement for the post of Sub Inspector (OSINT) and whether the selection process was arbitrary.
Ratio Decidendi: An applicant must meet the exact essential educational qualifications stipulated in the recruitment advertisement; failing which, their selection is not permissible, and the appellate court will not substitute its own view for the prescribed criteria when there is no underlying illegality in the procedure.
Result: Appeal dismissed.
| Table of Content |
|---|
| 1. overview of recruitment challenges and the initial writ petition. (Para 1 , 2 , 3) |
| 2. arguments regarding educational qualification fulfillment and merit. (Para 4 , 5) |
| 3. court verifies technical qualification criteria against advertisement specifications. (Para 6 , 7 , 8) |
| 4. assessment of recruitment process and reservation policy application. (Para 9 , 10 , 11) |
| 5. dismissal of appeal confirming validity of original rejection. (Para 12 , 13) |
AMARJOT BHATTI, J.
1. Present intra-court appeal has been filed by the appellant against judgment dated 12.12.2025 passed by learned Single Judge, whereby CWP-21433-2023 filed by Karanbir Singh Deyea has been dismissed, holding that appellant/petitioner participated in selection process and there was no illegality or arbitrariness on the part of respondent-State.
2. As per the facts of the case, appellant/petitioner Karanbir Singh Deyea in pursuance of Advertisement No. 07 of 2021 dated 09.09.2021 (Annexure P-2) for recruitment of 267 vacancies of Sub Inspectors in the Technical and Support Services Cadre of Punjab Police, applied against vacancy, Domain-Information Technology Services (IT) Group-I under specialization of Open Source Intelligence (‘OSINT’). The copy of Punjab Police Technical and Support Services Cadre Group C Service Rules 2021 are appended as Annexure P-1. He belonged to reserved category and applied under Scheduled Caste (Ramdasia and other) category. Appellant/petitioner was holding Diploma in Computer Applications (Distance Education) from Lovely Professional University year 2019 (Annexure P-3), thus fulfilled educational qualification for appointment to the post advertised under OSINT category. Application Form of appellant/petitioner is Annexure P-4 and his Admit Card is Annexure P-5. As per advertisement, recruitment process was consisting of two phases i.e. Phase-I (Test 1 and Test 2) and Phase-II (Physical Measurement Test, Physical Screening Test and Documents Scrutiny). Respondents conducted Test 1 of Phase-I on 28.09.2022 and conducted Test 2 on 29.09.2022. He participated in both tests and was hopeful to clear the same. He cleared Phase-I test and provisional list for Phase-II test was uploaded. He was shortlisted for Phase-II examination. Relevant extract of provisional list is Annexure P-6. He participated in Physical Measurement Test. Copies of e-Admit Card and Physical Measurement Test Slip are Annexures P-7 and P-8 respectively. Thereafter, in November 2022, dates were given for documents verification, to be held between 12.12.2022 to 16.12.2022 (Annexure P-9). Documents of appellant/petitioner were verified on 13.12.2022. Finally, provisional select list of candidates was issued on 25.05.2023, according to which total 255 candidates were recommended for selection and name of appellant/petitioner was missing in the said list. Case of appellant/petitioner was further rejected by Appellate Authority for recruitment of Sub Inspectors in Technical and Support Services Cadre 2021.
3. Feeling aggrieved, appellant/petitioner filed Civil Writ Petition under Articles 226/227 of the Constitution of India in the nature of Certiorari for quashing of provisional select list of the post of Sub Inspector in the Technical and Support Services (TSS) Cadre 2021 dated 25.05.2023, same being illegal, arbitrary as well as quashing of order dated 22.12.2023 vide which appeal preferred by appellant/petitioner was rejected by Special DGP Community Affairs Division and Women & Child Affairs-cum-Appellate Authority (Recruitment) Technical & Support Services, Punjab, being illegal and arbitrary by wrongly relying upon the conditions of advertisement having no relation to the reservation to be provided as per the conditions of advertisement, with further prayer to issue writ in the nature of Mandamus, directing respondents to consider the candidature of petitioner as valid and eligible for the post of Sub Inspector in the Technical and Support Services (TSS) Cadre 20
