P&H HC Directs DGP to Scrutinize Videography of Parade Test Amid Bias Allegations in Police Promotions: Punjab Police Rules 13.7

Introduction

In a significant ruling on service matters, the Punjab and Haryana High Court has directed the Director General of Police (DGP), Haryana , to investigate the videography of a 2014 parade test conducted for promotions within the Haryana Police . The decision addresses allegations of bias and irregularity in the evaluation process, particularly concerning two pregnant candidates who petitioner Seema Rani claims could not have participated yet received qualifying marks. Presided over by Hon'ble Mr. Justice Jagmohan Bansal, the court disposed of the petition filed under Articles 226/227 of the Constitution , emphasizing the need for higher-level scrutiny without granting direct relief to the petitioner.

Case Background

Seema Rani, recruited as a Constable in the Haryana Police in 2007 , participated in the 2014 Lower School Course competition under the 55% quota for promotions to Head Constable. She excelled in the written examination, securing 55 out of 60 marks and topping the test among 86 lady constables, of whom 30 qualified. However, under Rule 13.7 of the Punjab Police Rules, 1934 (applicable to Haryana), candidates must secure at least 50% (10 out of 20) marks in the subsequent parade test—a physical efficiency evaluation including a 1500-meter race, turnout, rifle exercise, squad drill, and word of command. Rani scored only 7.5 marks and was not called for the interview stage.

Out of the 30 who qualified the written test, 22 cleared the parade test, and 7 were ultimately selected. Rani alleged that two selected candidates (private respondents Nos. 5 and 6) were in advanced stages of pregnancy—six months and nine days, and four months and ten days, respectively—at the time, making participation impossible, especially in the race. She claimed they were awarded qualifying marks without participating and that she was denied access to the test's videography, which could expose the irregularity. In 2017 , Rani again topped the written test and was selected, underscoring her competence and suggesting discrimination in 2014 . The petition, filed as CWP-19480-2015 and decided on February 3, 2026 , sought her promotion as Head Constable from December 28, 2014 , with adjusted seniority.

Arguments Presented

The petitioner's counsel argued that Rani's top performance in the written test demonstrated her overall merit, yet she was unfairly awarded sub-qualifying marks in the parade test, indicating intentional discrimination . They highlighted the pregnancies of the private respondents, asserting it was physically impossible for them to complete the 1500-meter race or other drills, yet they scored 12 marks each—above the 10-mark threshold—enabling their interview and selection. The counsel emphasized the videography of the event, claiming denial of access hid the non-participation and undue favoritism, violating principles of fairness in promotions. They pointed to Rani's 2017 success as evidence of her capability and bias in the 2014 process.

In response, the State counsel, represented by the Additional Advocate General, maintained that Rani failed the parade test with 7.5 marks, below the required 10, justifying her exclusion from the interview. The private respondents, they noted, legitimately scored 12 marks each through performance in non-race components like turnout, rifle exercise, squad drill, and word of command. The State submitted an affidavit from the Deputy Commissioner of Police, Gurugram , confirming the pregnancies but argued this did not preclude participation in all elements, as zero marks were awarded to both private respondents and Rani in the race component. They asserted no irregularity occurred, and video evidence was not placed on record by either side.

Legal Analysis

The court carefully examined the marksheets, noting that zero marks were given to all parties in the 1500-meter race, precluding any immediate inference of non-participation by the pregnant candidates based solely on scoring. Justice Bansal clarified that excelling in the written test does not entitle a candidate to minimum qualifying or maximum marks in the practical parade test, as performance in theoretical and physical evaluations inherently differs. The ruling underscored Rule 13.7's mandate for at least 50% in the parade test as a distinct qualification criterion, independent of written scores.

No specific precedents were cited in the judgment, but the court's reasoning aligned with established administrative law principles of natural justice and fairness in service selections, requiring objective evaluation without bias. It distinguished between written aptitude and physical efficiency, rejecting assumptions of entitlement based on one stage's success. The allegations of intentional low scoring for the petitioner and undue marks for others warranted factual verification, leading to the directive for video scrutiny rather than quashing the process outright. This approach balances judicial restraint in service disputes with the need to probe potential irregularities, ensuring promotions under statutory rules like the Punjab Police Rules remain transparent.

Key Observations

• "In the absence of video, this Court cannot conclude that petitioner despite best performance was intentionally awarded marks less than qualifying or private respondents were awarded marks without participation."
• "A candidate merely on the ground that he or she has scored maximum marks in written test cannot claim that he or she should be awarded minimum qualifying or maximum marks in the practical test. The performance in written test is always different from performance in practical/physical test."
• "The private respondents were not awarded marks in 1500 meter race, thus, this Court at this stage cannot conclude that private respondents did not participate in the parade test."
• "Video needs to be examined by some higher officer to ascertain whether private respondents participated in the selection process or not. The authority further needs to examine whether petitioner was intentionally awarded lower marks than qualifying marks."

Court's Decision

The Punjab and Haryana High Court disposed of the petition without granting direct promotion or other relief to Seema Rani, instead issuing a targeted directive to the Director General of Police, Haryana. The DGP must determine if the 2014 parade test was videographed and, if footage exists, re-examine it to verify the private respondents' participation and whether the petitioner was deliberately under-marked. Any necessary further action must be taken within three months from February 3, 2026 , based on the scrutiny's outcome.

This decision promotes accountability in police recruitment processes by mandating higher-level review of potential biases, particularly in physical tests where vulnerabilities like pregnancy may arise. It could set a precedent for demanding videographic evidence in service selections, potentially deterring irregularities and enhancing trust in promotions under rules like 13.7. For future cases, it signals courts' willingness to intervene for verification without preempting administrative functions, affecting how physical efficiency tests are documented and evaluated in Haryana Police and similar forces.