State Of Haryana And Another v. Sandeep Singh And Others, Supreme Court Of India, Judgment, Law, casemine.com

Citation Codes

Neutral Citations

2019 INSC 628

Equivalent Citations

citation codes

Case Number

Civil Appeal No. 4546 of 2019†, decided on May 6, 2019

Disposition

allowed

Attorney(S)

Arun Bhardwaj, Additional Advocate General, Rameshwar Singh Malik, Senior Advocate (Ashish Pandey, Vishwa Pal Singh, Harikesh Singh, Ms Beena and Satish Kumar, Advocates) for the appearing parties.

Judges

Dr D.Y. Chandrachud
Hemant Gupta, JJ.

Acts

Section 5, Subsection 2 of the 1983 Income Tax Act
Article 21-A of the Constitution
Article 226 of the Constitution

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Smart Summary

Factual and Procedural Background

The appeal challenges the order dated 3 December 2014 of the Division Bench of the Punjab and Haryana High Court rendered in an intra-court appeal under Clause X of the Letters Patent. The respondents (original writ petitioners) are Drawing Teachers classified as Classical & Vernacular (C&V) teachers under the Haryana State Education School Cadre (Group C) Service Rules, 1998 (“1998 Rules”).

With the advent of the Haryana School Education (Group C) State Cadre Service Rules, 2012 (“2012 Rules”), Rule 9(5) stated that existing C&V teachers “shall be converted to TGT in the relevant subject”. Two juniors of the writ petitioners were promoted as Elementary School Headmasters. Claiming parity, the writ petitioners sought promotion from the same date, asserting that they now formed part of the Trained Graduate Teacher (TGT) cadre.

The Single Judge accepted their claim. The State’s intra-court (Letters Patent) appeal was dismissed by the Division Bench, affirming that C&V teachers, being “converted to TGT”, fell within the 85% promotional quota for TGTs to the post of Elementary School Headmaster. The State has now preferred the present appeal against that decision.

Legal Issues Presented

Whether C&V teachers “converted to TGT” by virtue of Rule 9(5) of the 2012 Rules become members of the TGT cadre for all purposes, including eligibility for promotion to Elementary School Headmaster.
Whether the High Court erred in holding that such teachers were entitled to promotion retrospectively from the dates on which their juniors were promoted.

Arguments of the Parties

Appellant – State

Rule 9(5) grants C&V teachers only a notional designation of TGT to prevent an anomalous situation after the 1998 Rules were repealed; it does not merge them into the TGT cadre.
Under the 1998 Rules, the promotional channel for C&V teachers was to the post of Master, which is the equivalent of a TGT. Thus, Masters—not C&V teachers—fit the definition of TGT under Rule 2(h) of the 2012 Rules.
C&V teachers lack essential TGT qualifications prescribed by the 2012 Rules (e.g., graduation, B.Ed., HTET/STET). Treating them as TGTs would collapse the distinction between feeder and promotional posts.

Respondents – Writ Petitioners

Rule 9(5) is explicit: upon commencement of the 2012 Rules, C&V teachers “shall be converted to TGT”. No qualification is attached to this deeming fiction.
Once converted, they indisputably fall within the 85% promotional quota reserved for TGTs to become Elementary School Headmasters, provided they possess the requisite B.A. and B.Ed. qualifications (which they do).

Table of Precedents Cited

No precedents were cited in the provided opinion.

Court's Reasoning and Analysis

The court found the High Court’s interpretation “simplistic”. It conducted a cumulative reading of the 2012 Rules, emphasising the interplay of:

Rule 2(h) – defining “TGT” to include only Masters appointed before 11 April 2012 and teachers appointed after that date;
Rule 7 and Appendix B – prescribing mandatory educational qualifications and experience for TGTs; and
Rule 9 – specifying promotional quotas and channels.

Key analytical steps:

The post of Master under the 1998 Rules (now equated with TGT) was itself a promotion post for C&V teachers; therefore, C&V teachers and TGTs are situated in distinct, hierarchical cadres.
Rule 9(5)’s phrase “converted to TGT” is construed as an administrative device to continue governing service conditions of a “dying cadre”, not as an elevation into the TGT cadre.
The rule intentionally omits the word “cadre”, signalling that C&V teachers were not to be amalgamated into the TGT promotional stream.
Allowing automatic elevation would defeat the legislative intent to enhance educational standards by staffing elementary schools with trained graduate teachers rather than erstwhile C&V teachers whose entry-level qualifications were lower.
C&V teachers remain eligible to compete for TGT posts through direct recruitment or promotion once they satisfy the higher qualifications; they cannot, however, claim parity merely by operation of Rule 9(5).

Holding and Implications

Appeal Allowed; High Court orders set aside.

Immediate effect: the writ petitioners are not entitled to promotion as Elementary School Headmasters on the basis that they were automatically absorbed into the TGT cadre. Broader implication: Rule 9(5) is clarified as a transitional provision; C&V teachers must meet full TGT qualifications to enter that cadre. No new precedent is set beyond interpretative guidance on the 2012 Rules.

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State Of Haryana And Another v. Sandeep Singh And Others

Hemant Gupta, J.— The challenge in the present appeal is to an order dated 3-12-2014 2014 SCC OnLine P&H 23142 passed by the Division Bench of the High Court of Punjab and Haryana in an intra-court appeal under Clause X of the Letters Patent.

2. The grievance of the respondents (hereinafter referred to as “the writ petitioners”) in the writ petition filed under Article 226 of the Constitution is that the post of Drawing Teacher had been converted to Trained Graduate Teacher (TGT) under Rule 9(5) of the Haryana School Education (Group C) State Cadre Service Rules, 2012 (“the 2012 Rules”). Two juniors to the writ petitioners have been promoted as Elementary School Headmasters, therefore, the writ petitioners are also entitled to get promoted from the day their juniors were promoted.

3. The contention of the writ petitioners is that they possess senior secondary qualification with 2 years' Diploma in Art & Craft and that they also possess qualification of BA and BEd. Initially, services of the writ petitioners were governed by the Haryana State Education School Cadre (Group C) Service Rules, 1998 (the 1998 Rules) which have since been replaced by the 2012 Rules. In terms of Rule 9(5) of the 2012 Rules, the Classical & Vernacular (C&V) Cadre teachers, such as the writ petitioners, are deemed to be converted to TGT in the relevant subject though no further recruitment shall be conducted to these categories of C&V teachers. The contention of the writ petitioners is that they fulfil the qualification prescribed for the post of Elementary School Headmaster, therefore, they are entitled to be considered for promotion to the said post based upon seniority in terms of Rule 11 of the 2012 Rules.

4. The stand of the State is that the writ petitioners are not entitled for promotion to the post of Elementary School Headmaster as they do not fulfil the requisite qualification for appointment to the post of TGT under the 2012 Rules.

5. The learned Single Bench relying upon Rule 9(5) of the 2012 Rules held 2014 SCC OnLine P&H 10201 that the C&V teachers stand converted to TGT cadre, therefore, they would be entitled to consideration for promotion to the post of Elementary School Headmaster. It was held as under: (Sandeep Singh case 2014 SCC OnLine P&H 23142, SCC OnLine P&H)

“As per Rule 9 of the 2012 Rules, for promotion to the post of Elementary School Headmaster, 85% posts have been kept reserved for promotion from amongst the TGTs. Since the petitioners now belong to the TGT cadre, they would be entitled to consideration for promotion to the post of the Elementary School Headmaster provided they fulfil the qualifications for the post, for which they are claiming promotion. The eligibility for promotion to the post of Elementary School Headmaster is BA BEd and since the petitioners fulfil the requisite qualifications for the said post, they are entitled to be considered for promotion to the said post according to their seniority, which has to be determined by the respondents as per Rule 11 of the 2012 Rules.”

6. The intra-court appeal preferred by the State was dismissed for the reason that once C&V teachers have been considered as the members of TGT cadre they cannot be denied the promotion post of Elementary School Headmaster against 85% quota earmarked for TGTs.

7. The learned counsel for the appellant argued that Rule 9(5) of the 2012 Rules only gives a notional designation of TGT to C&V teachers appointed under the 1998 Rules and that Rule 9(5) of the 2012 Rules cannot be read in isolation. It is contended that under the 1998 Rules, there were C&V teachers and Masters. The equivalent post of TGT in the 1998 Rules is Master, which is promotion post of C&V teachers such as the writ petitioners. A cumulative reading of various provisions of the 2012 Rules does not contemplate to treat C&V teachers as TGT, the Master being a promotion post for C&V teachers.

8. The minimum educational qualification for C&V teachers in terms of the 1998 Rules in the subject of Drawing was matric from Haryana School Education Board or equivalent qualification recognised by the Haryana School Education Board as well as 2 years' Diploma in Art and Craft Examination, whereas, for the promotion to the post of Art Master, the minimum qualification is BA with Art as one of the elective subject and BT/BEd from a recognised university or matric/10+2 with 5 years' degree/diploma from a recognised university.

9. It is contended that TGTs under the 2012 Rules are defined to mean the teachers appointed in the relevant subject after framing of the 2012 Rules and also include Masters appointed before the notification of these Rules. It is only the Master who falls within the definition of TGT under the 2012 Rules, whereas, the C&V teachers are converted to TGT notionally as dying cadre to avoid anomalous situation of the C&V teachers without being in any cadre.

10. The qualification for an appointment of TGT is Graduation; BEd and certificate of having qualified Haryana Teachers Eligibility Test (HTET)/School Teachers Eligibility Test (STET). The writ petitioners cannot be treated to be the members of TGT cadre under the 2012 Rules as the post of Master is equivalent to the Post of TGT, which is in fact, a promotion post for C&V teachers under the 1998 Rules.

11. On the other hand, the learned Senior Counsel for the writ petitioners supported the reasoning given by the High Court that once the C&V teachers are converted to TGT, therefore, they have to be treated as the members of TGT cadre itself and Rule 9(5) of the 2012 Rules cannot be given any other meaning as the language of the Rules leaves no manner of doubt that the C&V teachers are now to be deemed to be part of TGT cadre.

12. The relevant Rules need to be extracted at this stage to appreciate the respective contention of the parties. The relevant provisions of the 1998 Rules read as under:

“6. Appointing Authority.—(1) Appointments to the posts in the Service in case of Middle School Headmaster, Social Studies Master, Science Master, Mathematics Master, Agriculture Master, Commerce Master, Demonstrator in Physical Education (P.T. Master), Home Science Master, Art Master and Music Master shall be made by Joint Director Schools.

(2) Appointments to the posts in the Service in case of Sanskrit Teacher, Hindi Teacher, Punjabi Teacher, Physical Training, Instructor, Art and Craft Teacher (Drawing Teacher), Tailoring Teacher and Tabla Player shall be made by the respective District Education Officers of the District concerned.

***

9. Method of recruitment.—(1) Recruitment in the service shall be made:—

(a) in the case of Middle School Headmaster,

(i) by promotion from amongst Master; or

***

(b) in the case of Social Study Masters—

(i) 50% by promotion from amongst JBT and C&V teachers; and

(ii) 50% by direct recruitment; or

(iii) by transfer of deputation of an official already in service of any State Government or the Government of India;

(c) in the case of Science Master—

(i) 20% by promotion from amongst the JBT and C&V Teacher; and

(ii) 80% by direct recruitment; or

(iii) by transfer or deputation of an official already in service of any State Government or the Government of India;

(d) in the case of Mathematics Master,—

(i) 20% by promotion from amongst JBT an C&V teachers; and

(ii) 80% by direct recruitment; or

(iii) by transfer or deputation of an official already in the Service of any State Government or the Government of India;

(e) ***

(o) in the case of Art and Craft Teacher (Drawing Teacher)—

(i) by direct recruitment; or

(ii) by transfer or deputation of an official already in the service of any State Government or the Government of India;

***

appendix-b

(See Rule-3)

Sl. No. Designation of Posts Academic qualifications and experience if any for direct recruitment Academic qualifications and experience if any for appointment other than by direct recruitment 1-8. * * * 9 Art Master (i) BA with Art as one of the Elective Subject and BT/BEd from a recognised university. or Matric/10+2 with 5 years' degree/diploma in Arts from a recognised university; and (ii) knowledge of Hindi up to Matric Standard (i) BA with Art as one of the Elective subject and BT/BEd from recognised university. or Matric/10+2 with 5 years' degree/diploma in Arts from a recognised university; and or Matric/10+2 with 5 years' degree/diploma in Arts from a recognised university; and (ii) Knowledge of Hindi up to Matric Standard (iii) 3 years' experience on the post of JBT and C&V teacher. 10-14. * * * 15. Art and Craft Teacher (Drawing Teacher) (i) Matric from Haryana School Education Board or an equivalent qualification recognised by the Haryana School Education Board; (ii) 2 years' Diploma in Art and Craft Examination conducted by the Haryana Industrial Training Department or an equivalent (i) Matric from Haryana School Education Board or an equivalent qualification recognised by the Haryana School Education Board; (ii) 2 years' Diploma in Art and Craft Examination conducted by the Haryana Industrial Training Department or an equivalent

qualification recognised by the Haryana School Education Board; (iii) Knowledge of Hindi up to Matric Standard. qualification recognised by the Haryana School Education Board; (iii) Knowledge of Hindi up to Matric Standard.”

13. The similar qualifications exist for appointment to the other categories of C&V teachers and of promotion to the post of Masters.

14. The 1998 Rules were repealed when the 2012 Rules were notified on 11-4-2012. The relevant extracts from such Rules are as under:

“2. Definitions.—In these Rules, unless the context otherwise requires—

***

(e) “direct recruitment” means an appointment made otherwise than by promotion from within the service or by transfer of an official already in the service of the Government of India or any State Government.

***

(h) “TGT” means Trained Graduate Teacher in the relevant subject appointed after notification of these Rules and shall include masters appointed before notification of these Rules;

(i) “PRT” means Primary Teacher appointed after notification of these Rules and shall include junior basic teachers (JBT) appointed before notification of these Rules.

***

3. Number and character of posts.—The Service shall comprise of the posts shown in Appendix A to these Rules:

Provided that nothing in these Rules shall affect the inherent right of Government to make additions to or reductions in, the number of such posts or to create new posts with different designations and scales of pay, either permanently or temporarily.

***

7. Qualifications.—No person shall be appointed to any post in the Service, unless he is in possession of qualifications and experience specified in Column 3 of Appendix B to these Rules in the case of direct recruitment on contract basis and those specified in Column 4 of the aforesaid Appendix in the case of persons appointed other than by direct recruitment on contractual basis:

Provided that in case of on contractual basis direct recruitment, if the required number of candidates of Scheduled Caste, Backward Class, other backward classes, Ex-Servicemen and physically handicapped having not the required experience are not available against the vacancies reserved for them, then relaxation in experience up to the limit of fifty per cent may by order, for reason to be recorded in writing, given at the discretion of the recruiting agency.

***

9. Method of recruitment.—(1) Recruitment in the Service shall be made—

(a) In the case of Elementary School Head Master—

(i) 85% by promotion from amongst TGTs; and

(ii) 7% by promotion from Hindi teachers; and

(iii) 7% by promotion from Sanskrit teacher; and

(iv) 1% by promotion from Punjabi teacher; or

(v) by transfer or deputation of an official already in service of any State Government, Government of India or from the Haryana State Education School Cadre (Group C) Service;

(b) to (k) ***

(l) in the case of TGT Art—

(i) 67% by direct recruitment on contract basis; and

(ii) 33% by promotion from amongst Primary Teachers (PRTs)/Classical & Vernacular (C&V) Teachers; or

(iii) by transfer or deputation of an official already in service of any State Government, Government of India;

***

(5) The present Classical & Vernacular (C&V) cadre consisting of the posts of Sanskrit Teachers, Hindi Teachers, Punjabi Teachers, Physical Training Instructors (PTIs), Art & Craft Teachers (Drawing Teachers), Tailoring Teachers and Tabla Players and governed by the Haryana State Education School Cadre (Group C) Service Rules, 1998 shall be converted to TGT in relevant subject and no further recruitment shall be made to these categories when the present incumbent on the notification of these Rules vacate the post on his promotion, retirement or any other purpose.

(emphasis supplied)

***

appendix A

(See Rule 3)

Sl. No. Designation of posts Number of posts Scale of pay Permanent Temporary Total Pay Band Grade Pay 1. Elementary School Head Master — 5207 5207 9300-34,800 4800 2. TGT Social Studies 5513 3307 8820 9300-34,800 4600 3. TGT Science 3014 1579 4593 9300-34,800 4600 4. TGT Mathematics 2566 2129 4695 9300-34,800 4600 5. TGT English — — — 9300-34,800 4600 6. TGT Hindi — — — 9300-34,800 4600

7. TGT Sanskrit — — — 9300-34,800 4600 8. TGT Punjabi — — — 9300-34,800 4600 9. TGT Urdu 1 0 1 9300-34,800 4600 10. TGT Physical Education 918 179 1097 9300-34,800 4600 11. TGT Home Science 167 129 296 9300-34,800 4600 12. TGT Art 0 1 1 9300-34,800 4600 13. TGT Music 58 33 91 9300-34,800 4600

appendix B

(See Rule 7)

Sl. No. Designation of posts Academic qualifications and experience, if any, for direct recruitment on contract basis Academic qualifications and experience, if any, for appointments other than by direct recruitment on contract basis 1. Elementary School Head Master — By Promotion— (i) BA/BSc and 2-year Diploma in Elementary Education; or BA/BSc with at least 50% marks and 1-year Bachelor in Education (BEd); or BA/BSc with at least 45% marks and 1-year Bachelor in Education (BEd), in accordance with the NCTE (Recognition Norms and Procedure) Regulations issued from time to time in this regard; or Senior Secondary (or its equivalent) with at least 50% marks and 4 year Bachelor

in Elementary Education (BElEd); or Senior Secondary (or its equivalent) with at least 50% marks and 4 year BAEd; or BA/BSc with at least 50% marks and 1-year BEd (Special Education); (ii) 5 years' experience in regular capacity Hindi/Sanskrit/Punjabi Teacher/TGT. (iii) At least 3 weeks' in-service training in administrative and accounts module. 2-11. * * * 12. TGT Art (i) BFA/BA and 2-year Diploma in Elementary Education; or BFA/BA with at least 50% marks and 1-year Bachelor in Education (BEd); or BFA/BA with at least 45% marks and 1-year Bachelor in Education (BEd); in accordance with the NCTE (Recognition Norms and Procedure) Regulations issued from time to time in this regard; or Senior Secondary (or its equivalent) with at least 50% marks and By Promotion— (i) BFA/BA and 2-year Diploma in Elementary Education; or BFA/BA with at least 50% marks and 1-year Bachelor in Education (BEd); or BFA/BA with at least 45% marks and 1-year Bachelor in Education (BEd), in accordance with the NCTE (Recognition Norms and Procedure) Regulations issued from time to time in this regard; or Senior Secondary (or its equivalent) with at least

4 year Bachelor in Elementary Education (BEl Ed); or Senior Secondary (or its equivalent) with at least 50% marks and 4 year BAEd; or BFA/BA with at least 50% marks and 1-year BEd (Special Education); and (ii) in case of BA Arts, at least 50% marks in Fine Arts as an Elective subject, (iii) in case of BEd, Fine Arts as a teaching subject from a recognised University; (iv) Certificate of having qualified Haryana Teacher Eligibility Test (HTET)/School Teachers Eligibility Test (STET). (v) Matric with Hindi/Sanskrit or 10+2/BA/MA with Hindi as one of the subject. 50% marks and 4 year Bachelor in Elementary Education (BElEd); or Senior Secondary (or its equivalent) with at least 50% marks and 4 year BAEd; or BFA/BA with at least 50% marks and 1-year BEd (Special Education); and (ii) In case of BA Arts, at least 50% marks in Fine Arts as an Elective subject, (iii) In case of BEd, Fine Arts as a teaching subject from a recognised University; (iv) 3 years' experience as Primary Teacher (PRT)/Classical & Vernacular (C&V) Teacher. (v) Certificate of having qualified Haryana Teacher Eligibility Test (HTET)/School Teachers Eligibility Test (STET).”

15. We find that the High Court has taken a simplistic view on the bare reading of Rule 9(5) of the 2012 Rules to hold that with the commencement of the 2012 Rules, the C&V teachers become part of TGT cadre and as part of the TGT cadre, they become entitled for promotion to the post of Elementary School Headmaster from the day their juniors were promoted to such post.

16. The appointment of the writ petitioners as C&V teacher is prior to the commencement of the 2012 Rules. The 1998 Rules contemplate direct recruitment to the post of Master and to various other disciplines, commonly called as C&V teachers. In fact, the post of Master is a promotion post for C&V teachers in terms of Rule 9 of the 1998 Rules. The qualification for the post of Art Master by way of direct recruitment and promotion is graduate or matric/10+2 with 5 years' degree/diploma. However, for promotion the additional qualification is 3 years' experience on the post of JBT and C&V teachers.

17. The post of TGT is contemplated to be filled up by direct recruitment and by promotion from amongst primary teachers/C&V teachers. Column 3 of Appendix B of the 2012 Rules prescribes the academic qualifications and experience for direct recruitment on contract basis whereas, Column 4 prescribes academic qualifications and experience for appointment other than by direct recruitment on contract basis. The qualifications for filling up the post of TGT by way of promotion are BFA/BA and 2-year Diploma in Elementary Education; or BFA/BA with at least 50% marks and 1-year Bachelor in Education (BEd); or BFA/BA with at least 45% marks and 1-year Bachelor in Education (BEd); in accordance with the NCTE (Recognition Norms and Procedure) Regulations issued from time to time in this regard; or Senior Secondary (or its equivalent) with at least 50% marks and 4 year BAEd., etc. and 3 years' experience as Primary Teacher (PRT)/Classical & Vernacular (C&V) Teacher. Thus, the post of TGT is a promotion post for C&V teachers as well.

18. Therefore, the reading of the entire 2012 Rules shows that the Masters appointed under the 1998 Rules alone were holding equivalent post to that of the members of the cadre of TGT. It is such category alone who are entitled to be promoted to the post of Elementary School Headmaster in terms of the qualifications prescribed in Appendix B particularly in view of Rule 2(h) and Rule 7 of the 2012 Rules. TGT means a trained graduate teacher in the relevant subject appointed after notification of the 2012 Rules and include the Masters appointed before the notification of these Rules. Therefore, the Masters appointed in terms of the 1998 Rules are only the trained graduate teachers in terms of the 2012 Rules. The post of Master under the 1998 Rules or the Post of TGT under the 2012 Rules is in fact promotion post for the C&V teachers.

19. The entire argument of the appellants is based upon the expression used that C&V teachers governed by the 1998 Rules shall be “converted to TGT in relevant subject”. The question is whether such C&V teachers stand upgraded to the post of TGT though, their promotion channel under the 1998 Rules was to the post of Master which alone has been treated as TGT as defined in Rule 2(h) of the 2012 Rules and in view of express language of Rule 7 which mandates that the appointment shall be made to the post of TGT only in accordance with the qualifications prescribed in the 2012 Rules.

20. The reading of the Rules would show that C&V teachers are treated to be TGT so as to avoid anomalous situation where the C&V teachers after the commencement of the 2012 Rules would not be governed by any set of Rules. Therefore, the expression that such C&V teachers stand converted to TGT is only to facilitate their service conditions to be governed by the 2012 Rules rather than to upgrade the C&V teachers as members of TGT cadre. The feeder and the promotional cadre cannot be treated on a par by virtue of the expression used in Rule 9(5) of the 2012 Rules that the C&V teachers shall be converted to TGT. Such conversion is only for a limited purpose of the 2012 Rules being extended to them and that such C&V teachers do not become member of the “cadre” eligible for promotion as Elementary School Headmaster. Rule 9(5) of the 2012 Rules does not use the word “cadre”. Therefore, such teachers cannot be treated to be part of TGT cadre. Such interpretation is further supported by the fact that C&V Teacher is a dying cadre and no further recruitment is to be made in these categories.

21. Such C&V teachers, if eligible, can seek appointment by way of a direct recruitment or other than by direct recruitment in terms of the academic qualifications and experience contained in Appendix B of the 2012 Rules but they cannot be treated en masse as members of TGT cadre. The State may consider to provide opportunity to such teachers for appointment as TGTs.

22. The TGTs are engaged to provide elementary education. The purpose of the Rules is better served by ensuring education to the students of primary schools in the State by trained graduate teachers rather than C&V teachers who were being engaged earlier. It is upgradation of qualification of teachers to be engaged for teaching the students of the primary schools for appointment as TGTs. Therefore, the interpretation which subserves cause of education is to be preferred as against the interpretation leading to anomalous result, more so it is not warranted by the cumulative reading of the 2012 Rules.

23. In view of the above, we find that the order passed by the High Court that C&V teachers become member of the TGT cadre after the commencement of the 2012 Rules in fact violates the cumulative reading of the 2012 Rules and defeats the cause of the primary education in the State guaranteed by Article 21-A of the Constitution.

24. Consequently, the appeal is allowed and the order passed by the High Court is set aside.

State Of Haryana And Another v. Sandeep Singh And Others

Factual and Procedural Background

Legal Issues Presented

Arguments of the Parties

Appellant – State

Respondents – Writ Petitioners

Table of Precedents Cited

Court's Reasoning and Analysis

Holding and Implications

State Of Haryana And Another v. Sandeep Singh And Others

Comments