01Facts
The petitioner applied for the post of Librarian (Category No. 03) under Advertisement No. 12/2019.
p. 3The prescribed qualifications included a bachelor’s degree in Library Science and two years’ experience as a Junior Librarian in a reputed institute.
p. 3His 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. 4–5Although 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. 1–302Issues
i.1. Whether the petitioner’s experience certificate established the prescribed two years’ experience as a Junior Librarian in a reputed institute.
pp. 4–6ii.2. Whether the Commission’s decision to treat the petitioner as ineligible warranted interference in judicial review.
pp. 6–8, 12–1403Law 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. 6–8The employer determines the qualifications required for a post, subject to review for matters such as arbitrariness or violation of law.
pp. 6–8Where 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. 7–804Reasoning
The Court accepted that the petitioner held the requisite degree, but treated the experience condition as an independent and mandatory requirement.
p. 10The 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, 10–12The 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, 10–12His position on the waiting list did not cure the failure to establish eligibility.
p. 1405Holding
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. 13–14The writ petition was dismissed, and any pending miscellaneous applications were also disposed of.
p. 15Original Court PDF
Manoj KumarvsHaryana Staff Selection Commission
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