Introduction

The case of Amarjeet Singh and Another v. State of Haryana and Another adjudicated by the Punjab & Haryana High Court on December 20, 1994, addresses significant issues surrounding the fairness and legality of selection processes employed by Public Service Commissions in India. The petitioners, Amarjeet Singh and Jaspal Singh, challenged their exclusion from a selection list for posts within the Haryana Agriculture Service Class II, alleging that the selection criteria applied by the Haryana Public Service Commission (HPSC) were arbitrary and violative of their fundamental rights under Articles 14 and 226/227 of the Constitution of India.

Summary of the Judgment

The petitioners, both holding B.Tech degrees in Agriculture Engineering with commendable academic records and substantial relevant experience, applied for positions advertised by the HPSC. Despite meeting the essential qualifications and performing satisfactorily in interviews, they were not recommended for appointment, which led them to challenge the selection process.

The High Court, upon reviewing the selection criteria and the process undertaken by HPSC, found that the allocation of marks—particularly the heavy emphasis on interview performance (75 out of 100 marks) while assigning negligible or no marks for higher qualifications and specialized training—was arbitrary. This disproportionate weighting rendered the selection process unfair, leading to the exclusion of more meritorious candidates like the petitioners.

Consequently, the court directed the HPSC to include the petitioners in the selection list and ensure their appointment, emphasizing the necessity for fair and balanced evaluation criteria in public service recruitment.

Analysis

Precedents Cited

The judgment references several Supreme Court rulings to evaluate the legality of the selection criteria:

• Neelima Shangla v. State of Haryana (1986): Emphasized that Public Service Commissions must provide a complete merit list based on fair evaluation criteria without arbitrary exclusions.
• Ajay Hasia v. Khalid Mujib Sehravardi (1981): Discussed the balance between written tests and interviews, ensuring that neither is disproportionately weighted unless justified.
• Kamal Kumar Gupta v. State of Haryana (1985) and others: Addressed the arbitrary allocation of marks and the necessity for transparent, non-discriminatory selection processes.

However, the court discerned that while these precedents critique overly burdensome interview requirements in combined selection processes, they did not directly apply to cases where selection was based solely on interviews without prior written tests.

Legal Reasoning

The High Court scrutinized the HPSC's methodology, particularly the allocation of 75% marks to interviews and a mere 25% to personal achievements (such as higher qualifications and experience). It noted that:

• The Commission failed to assign marks for higher qualifications and specialized training that none of the candidates possessed, rendering the interview portion effectively out of 85 marks instead of 100.
• This arbitrary reduction undermined the fairness of the selection process, as candidates like the petitioners who excelled in qualifications and experience were disadvantaged.
• Despite the Commission's autonomy in determining selection criteria, there exists a constitutional mandate to ensure that such criteria do not violate the principles of equality and fairness under Article 14.

The court concluded that the HPSC's criteria were arbitrary and thus unconstitutional, necessitating the inclusion of the petitioners in the selection list.

Impact

This judgment underscores the importance of balanced and transparent selection criteria in public service appointments. It sets a precedent that:

• Public Service Commissions must ensure that their evaluation frameworks are fair, non-arbitrary, and reflective of the true requirements of the position.
• Overemphasis on subjective measures like interviews, without adequate consideration of objective qualifications and experience, can be deemed unconstitutional.
• Future cases will likely refer to this judgment when challenging selection processes that appear biased or disproportionate in their evaluative components.

Complex Concepts Simplified

Article 14 of the Constitution of India

Article 14 guarantees equality before the law and equal protection of the laws within the territory of India. It mandates that any state action must not be arbitrary, discriminatory, or biased.

Public Service Commission

A Public Service Commission is a government body responsible for conducting examinations and making recommendations for appointments to various public sector positions. It ensures that recruitment is conducted fairly and based on merit.

Arbitrariness in Selection

Arbitrariness refers to actions taken without a valid reason or in a manner that is not based on established rules or fairness. In the context of this case, it pertains to the HPSC disproportionately weighting interview performance over qualifications and experience without justification.

Conclusion

The Amarjeet Singh v. State of Haryana case reinforces the constitutional imperative for fairness and equality in public service recruitment. It highlights that while Public Service Commissions possess the autonomy to design selection criteria, such frameworks must be balanced, transparent, and free from arbitrariness to uphold the fundamental rights of applicants. This judgment serves as a critical reference point for ensuring that merit-based appointments are conducted without bias, thereby fostering integrity and trust in public institutions.