Eligibility depends on acquiring the qualification before the cut-off date, not delayed certificate issuance.

The petitioner applied pursuant to Advertisement No. 4/2023 for recruitment to 104 posts of TGT Punjabi in the Department of Elementary Education, Haryana. The last date for submitting applications was 9 October 2023.

In his application, the petitioner disclosed that he had completed his B.Ed. from Kurukshetra University and that his result had been declared before the closing date.

Although his final DMC was dated/prepared and issued subsequently, the record showed that he had appeared in the second-year B.Ed. examination in July 2023 and that the result had been declared in September 2023.

The petitioner’s name was omitted from the final result dated 28 May 2026, leading him to invoke Articles 226 and 227 of the Constitution seeking quashing of the result to that extent and directions for appointment with consequential benefits.

Whether the petitioner could be treated as possessing the requisite B.Ed. qualification before the cut-off date when his examination result had been declared before that date but the formal DMC was prepared or issued later?

Whether the respondents were justified in excluding the petitioner from the final result and denying consideration for appointment solely on account of the subsequent issuance of the formal qualification document?

Whether the petitioner was entitled to appointment and consequential monetary and notional benefits, subject to his being otherwise eligible and meritorious?

The Court exercised its jurisdiction under Articles 226 and 227 of the Constitution of India to examine the legality of the petitioner’s exclusion from the recruitment process.

It applied the principle that, for determining educational eligibility, the relevant date is ordinarily the date on which the candidate passes the examination or the result is declared, and not the later date on which the university issues the formal certificate or DMC, particularly where the delay is procedural or administrative.

Relying on Harpreet Kaur v. State of Haryana and Others, LPA No. 612 of 2023, the Court held that recruitment agencies must consider the date and year of passing rather than the date of issuance of the certificate, and should not penalise candidates for institutional delays.

The Court also relied on Haryana Staff Selection Commission v. Priyanka and Others, (2022) 18 SCC 122, which establishes that a candidate possessing an authentic provisional or confidential result issued through the proper institutional channel before the cut-off date cannot be treated as ineligible merely because the university formally declared or processed the final result later.

The petitioner had disclosed his result particulars in the application and had uploaded the relevant B.Ed. documents.

The university records and the Deputy Registrar’s certificate established that he had completed the B.Ed. course and that his second-year result had been declared in September 2023, before the 9 October 2023 cut-off date, even though the DMC was prepared or issued later.

Applying Harpreet Kaur, the Court treated the date of passing/result declaration as determinative and regarded the later issuance of the DMC as a procedural delay attributable to the educational institution.

Applying Priyanka, the Court held that the petitioner could not be denied eligibility where the authenticity of his qualification and result was not disputed.

The respondents were directed to consider the petitioner’s claim for appointment to the post of TGT Punjabi in accordance with law, provided he was otherwise eligible and sufficiently meritorious.

If appointed, he was held entitled to actual salary from the date of joining.

He was also granted notional benefits, strictly according to his merit position and the applicable rules or instructions, from the date on which his immediate junior or counterpart joined service.