P&H HC Rejects Serving Engineers’ Challenge To General-Studies-Only Screening, Saying Civil Engineering Is Tested Separately

In brief

The question

1. Whether a screening-test syllabus confined to general subjects, with no Civil Engineering component, was irrational or lacked a nexus with the advertised engineering posts.

The court held

The Court held that the challenge to the general-subject screening syllabus lacked merit and dismissed the writ petition.

It also directed

Pending applications, if any, were also disposed of.

01Facts

The Haryana Public Service Commission (HPSC), through Advertisement No. 19/2025 dated 8 August 2025, invited applications for civil engineering posts, including Assistant Engineer (Civil) and Sub Divisional Engineer (Civil).

pp. 2–3

The screening-test syllabus announced on 22 August 2025 covered general subjects and excluded Civil Engineering.

pp. 2–3

Candidates who secured at least 25% would be shortlisted—up to four times the advertised vacancies—for a Subject Knowledge Test; screening-test marks would not count toward final selection.

pp. 7–8

The petitioners, including serving Assistant Engineers, challenged the advertisement and syllabus under Article 226, seeking a technical component in the screening test.

pp. 2–6

They argued that excluding the core subject was irrational, particularly given the posts’ technical duties and the HPSC’s earlier practice.

pp. 2–6

The HPSC opposed the petition, relying on an earlier coordinate-Bench decision concerning the same issue.

p. 6

02Issues

i.1. Whether a screening-test syllabus confined to general subjects, with no Civil Engineering component, was irrational or lacked a nexus with the advertised engineering posts.

pp. 7–9

ii.2. Whether the Court should intervene in the HPSC’s choice of screening subjects and substitute a technical screening component.

pp. 9–18

03Law Applied

Under Article 226, judicial review of recruitment policy is confined to legality, constitutionality and manifest arbitrariness; a court does not replace an employer’s assessment of the qualifications or selection criteria suited to a post.

Maharashtra Public Service Commission v. Sandeep Shriram Warade, (2019) 6 SCC 362, holds that the employer determines the qualifications and requirements for a post, and courts cannot rewrite clear recruitment criteria.

p. 12

Satya Dev Bhagaur v. State of Rajasthan, (2022) 5 SCC 314, reiterates that courts should not interfere with policy unless it is palpably discriminatory or arbitrary.

pp. 13–14

The judgment also relies on the principle that courts ordinarily defer to expert bodies on technical or academic matters, while retaining power to intervene for statutory or constitutional violations, mala fides, or arbitrary and capricious action.

pp. 15–17

It treated the coordinate-Bench ruling in Amit Ahalawat v. State of Haryana (CWP-32117-2025, decided 31 October 2025) as addressing the same issue.

pp. 9–10, 17–18

04Reasoning

The Court rejected the contention that the screening syllabus had no connection with the posts.

pp. 8–9

It reasoned that general science, current events, reasoning, numeracy and other listed subjects were not extraneous to the work, and that the petitioners’ own pleadings recognised the broader responsibilities of engineering officers.

pp. 8–9

It further held that the separate, technical Subject Knowledge Test addressed candidates’ Civil Engineering knowledge, while the screening test served to shortlist candidates.

pp. 7–8, 19

The HPSC was the expert body competent to select screening subjects, and the Court found no basis to substitute its judgment for the Commission’s.

pp. 9–18

It followed Amit Ahalawat, distinguished the Division Bench decision in HPSC v. Lakhan Singh as not governing the controversy, and found no ground for judicial intervention.

pp. 9–18