TGT Applicant’s 2018 Provisional Result Counts Despite Marksheet Issued After Application Deadline; P&H HC Orders Merit Review

The petitioner applied for the post of TGT Social Studies under an advertisement requiring 50% marks in the relevant qualification, with a 5% relaxation for specified categories, making the applicable threshold 47.5%.

His application included an earlier marksheet showing 45.75%. He had, however, appeared in a B.A. improvement examination in April 2018 and obtained 584 out of 1,200 marks (48.67%), as shown in a provisional result dated 14 August 2018. The formal improved marksheet was issued on 4 July 2023, after the application deadline of 15 March 2023.

The Commission declared him ineligible for having less than the required marks; he challenged that decision under Articles 226 and 227 of the Constitution.

Under the recruitment advertisement, the qualifying threshold was 50%, subject to a 5% relaxation for eligible reserved and differently abled candidates, resulting in a 47.5% threshold.

In Haryana Staff Selection Commission v. Priyanka, Civil Appeal Nos. 5065–5095 of 2021, decided 1 September 2021, the Supreme Court held that a provisional or confidential result declared before the cut-off date may establish eligibility where its authenticity is not in doubt.

In Harpreet Kaur v. State of Haryana, LPA-612-2023, decided 9 August 2024, the Division Bench held that recruitment authorities should ordinarily consider the date an examination was passed, rather than the later date on which the certificate was issued, while addressing any genuine doubt about authenticity through verification.

The petitioner’s provisional result recorded 584 marks out of 1,200 in the B.A. improvement examination, equivalent to 48.67%, and was dated 14 August 2018—well before the 15 March 2023 cut-off.

The Court applied Priyanka and Harpreet Kaur to distinguish the date on which the qualification was acquired from the later issue of the formal marksheet. Because the provisional result evidenced that the petitioner had obtained marks above the applicable 47.5% threshold before the cut-off, the later issuance of the marksheet did not, by itself, render him ineligible.

The Commission was directed to treat him as eligible on the basis of the provisional result and reassess his merit; appointment is required only if he falls within the zone of selection. If appointed, he is entitled to notional pay fixation and seniority, but not salary for the period before actual joining; the exercise was directed to be completed, preferably, within four weeks of receipt of the order.