Punjab and Haryana High CourtAdministrative and Public LawEmployment and Labour Law

Army Ex-Serviceman’s Bid for Librarian Post Fails: P&H HC Says Certificate Didn’t Prove 2 Years as Junior Librarian

Manoj Kumarv.Haryana Staff Selection Commission

Army Ex-Serviceman’s Bid for Librarian Post Fails: P&H HC Says Certificate Didn’t Prove 2 Years as Junior Librarian. Manoj Kumar vs Haryana Staff Selection Commission. Punjab and Haryana High Court. LawLens
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In brief

The question

1. Whether the petitioner’s experience certificate established the prescribed two years’ experience as a Junior Librarian in a reputed institute.

The court held

The Court held that the petitioner had not established two years’ experience as a Junior Librarian in a reputed institute and found no ground to interfere with the Commission’s decision.

It also directed

The writ petition was dismissed, and any pending miscellaneous applications were also disposed of.

01Facts

The petitioner applied for the post of Librarian (Category No. 03) under Advertisement No. 12/2019.

p. 3

The prescribed qualifications included a bachelor’s degree in Library Science and two years’ experience as a Junior Librarian in a reputed institute.

p. 3

His Indian Army experience certificate recorded service from 1 January 2004 to 31 March 2019 and referred generally to library-related duties, but did not specify their duration or state that he served as a Junior Librarian.

pp. 4–5

Although he was placed first on the waiting list for the ESM BCB category, the Commission treated him as ineligible; his challenge to the final result and the subsequent rejection of his claim was brought under Articles 226 and 227.

pp. 1–3

02Issues

i.1. Whether the petitioner’s experience certificate established the prescribed two years’ experience as a Junior Librarian in a reputed institute.

pp. 4–6

ii.2. Whether the Commission’s decision to treat the petitioner as ineligible warranted interference in judicial review.

pp. 6–8, 12–14

03Law Applied

Under Articles 226 and 227, judicial review of recruitment decisions does not permit a court to rewrite clear eligibility criteria, substitute its assessment for that of the recruiting authority, or determine equivalence where that matter lies within the employer’s domain.

pp. 6–8

The employer determines the qualifications required for a post, subject to review for matters such as arbitrariness or violation of law.

pp. 6–8

Where an advertisement prescribes a separate, mandatory experience requirement, a candidate must establish that the experience shown meets that requirement; merit or placement on a waiting list does not dispense with eligibility.

pp. 10–14

*Maharashtra Public Service Commission v. Sandeep Shriram Warade*, (2019) 6 SCC 362

pp. 6–7

*M.D. Firoz Mansuri v. State of Bihar*, 2026 INSC 68

pp. 7–8

04Reasoning

The Court accepted that the petitioner held the requisite degree, but treated the experience condition as an independent and mandatory requirement.

p. 10

The certificate showed general Army service and mentioned library-related activities, yet did not identify the period during which those duties were performed or establish that the petitioner performed them as a Junior Librarian.

pp. 5–6, 10–12

The Court therefore could not presume the required duration or nature of experience, or treat general library-related duties as equivalent to the specifically prescribed experience.

pp. 5–6, 10–12

His position on the waiting list did not cure the failure to establish eligibility.

p. 14

05Holding

The Court held that the petitioner had not established two years’ experience as a Junior Librarian in a reputed institute and found no ground to interfere with the Commission’s decision.

pp. 13–14

The writ petition was dismissed, and any pending miscellaneous applications were also disposed of.

p. 15
Punjab and Haryana High Court

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Manoj KumarvsHaryana Staff Selection Commission

Punjab and Haryana High Court · November 02, 2026

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