Punjab and Haryana High CourtConstitutional LawEmployment and Labour Law

After Junior Promotees Got Stations Earlier Withheld For Low Student Strength, P&H HC Bars Haryana From Restricting Principals’ Transfer-Drive Participation

Hazari Lal And Othersv.State Of Haryana And Anr

After Junior Promotees Got Stations Earlier Withheld For Low Student Strength, P&H HC Bars Haryana From Restricting Principals’ Transfer-Drive Participation. Hazari Lal And Others vs State Of Haryana And Anr. Punjab and Haryana High Court. LawLens
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In brief

The question

Whether the use of a student-strength threshold to restrict the petitioners’ choice of stations, while later allowing junior Principals to opt for those stations, amounted to arbitrary or discriminatory treatment under Articles 14 and 16 of the Constitution

The court held

Both writ petitions were disposed of in terms of the State’s undertaking.

It also directed

The respondents were directed to permit all eligible Principals, including the petitioners, to participate in the forthcoming transfer drive without using student strength to restrict participation or create an artificial classification among Principals of the same cadre, and to adhere to the promised schedule

The order dated 30 October 2026 was modified to that extent; non-compliance would entitle the petitioners to seek appropriate relief under Article 215

01Facts

The petitioners, Post Graduate Teachers promoted as Principals in the Rest of Haryana Cadre, received temporary stations through online counselling in November 2024.

p. 2

The Department offered 478 stations, excluding certain schools with fewer than 484 students

pp. 2–3

In later promotion exercises in May and December 2025, those excluded stations were offered to newly promoted Principals, including juniors to the petitioners.

p. 3

The petitioners challenged the different treatment, contending that the student-strength criterion was arbitrary and discriminatory.

pp. 3–8

In its order of 29 September 2026, the Court recorded concerns about the absence of a justification for treating the two groups differently and granted the State a further opportunity to provide instructions.

pp. 3–8

At the final hearing, the State undertook to hold a transfer drive, allow all eligible Principals—including the petitioners—to participate without using student strength to restrict participation or classify Principals within the same cadre, and issue the schedule within one month.

p. 8

02Issues

i.Whether the use of a student-strength threshold to restrict the petitioners’ choice of stations, while later allowing junior Principals to opt for those stations, amounted to arbitrary or discriminatory treatment under Articles 14 and 16 of the Constitution

pp. 3–7

ii.Whether the petitioners should be permitted to participate in the forthcoming transfer drive without student strength being used to restrict participation or create classifications among Principals in the same cadre

p. 8

03Law Applied

Articles 14 and 16 prohibit arbitrary State action and require equal treatment in matters of public employment; a classification must rest on an intelligible differentia having a rational nexus with its object

pp. 4–6

The Court’s earlier discussion referred to State of Kerala v. M. Vijayakumar, 2026 INSC 352, which restated that the State must establish the rational basis for a classification and its connection to the object pursued; it also referred to State of Punjab v. Davinder Singh, (2025) 1 SCC 1, and Ajay Hasia v. Khalid Mujib Sehravardi, (1981) 1 SCC 722

pp. 4–6

Article 215 was cited in the final order as the basis for seeking contempt proceedings in the event of non-compliance

p. 8

04Reasoning

The Court’s earlier order noted that the petitioners and the later-promoted Principals belonged to the same cadre, and that the State had not identified a real difference justifying the different treatment.

pp. 6–7

It also observed that the State had not explained why stations withheld due to low student numbers were offered in subsequent exercises, or shown a relevant change in circumstances

pp. 6–7

At the final hearing, however, the State undertook to remove student strength as a ground for restricting eligible Principals’ participation in the forthcoming transfer drive.

p. 8

The Court therefore disposed of the petitions on that undertaking, without further adjudicating the merits.

p. 8

05Holding

Both writ petitions were disposed of in terms of the State’s undertaking.

p. 8

The respondents were directed to permit all eligible Principals, including the petitioners, to participate in the forthcoming transfer drive without using student strength to restrict participation or create an artificial classification among Principals of the same cadre, and to adhere to the promised schedule

p. 8

The order dated 30 October 2026 was modified to that extent; non-compliance would entitle the petitioners to seek appropriate relief under Article 215

p. 8
Punjab and Haryana High Court

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Hazari Lal And OthersvsState Of Haryana And Anr

Punjab and Haryana High Court · November 11, 2026

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