Punjab and Haryana High Court Quashes HPSC ADA Screening Test Pattern for Ignoring Law Subjects, Terms It Arbitrary and Unconstitutional

By Shivam Y. • October 19, 2025

Punjab and Haryana High Court strikes down HPSC’s ADA exam syllabus for excluding law subjects, calling it arbitrary and against equal opportunity. - Lakhan Singh & Others vs State of Haryana & Others

In a significant judgment that could reshape recruitment norms for specialized legal posts, the Punjab and Haryana High Court at Chandigarh has quashed the screening test pattern announced by the Haryana Public Service Commission (HPSC) for the post of Assistant District Attorney (ADA). Justice Sandeep Moudgil delivered a 36-page verdict on October 17, 2025, holding that the commission's decision to exclude legal subjects from the screening test was 'irrational, arbitrary, and violative of Articles 14 and 16 of the Constitution.'

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"The State cannot hide arbitrariness behind the cloak of discretion," the judge remarked while allowing a bunch of writ petitions filed by several ADA aspirants, including Lakhan Singh, Navender, Aman Dalal, Harshvardhan Malik, and others.

Background

The controversy began when HPSC issued Advertisement No. 18 of 2025, inviting applications for 255 ADA posts in the Haryana Prosecution Department. A subsequent announcement on August 8, 2025, detailed a three-stage recruitment process-screening test, subject knowledge test, and interview.

However, candidates were shocked to learn that the first stage, the screening test, would include only general knowledge, reasoning, current affairs, and numeracy, without even a single question on law. Petitioners argued that for a post as specialized as ADA, such a syllabus "defeats the entire purpose of legal education."

Advocates appearing for the petitioners contended that HPSC had deviated from the earlier 2017 recruitment pattern, where 80% of the screening test covered law subjects. They accused the commission of acting without consultation or rationale.

Court's Observations

Justice Moudgil's detailed reasoning focused on three aspects-legality, fairness, and statutory compliance.

He observed that screening thousands of law graduates through a non-legal test "renders their degrees meaningless" and destroys the rational nexus between the selection method and the post’s essential qualifications.

"A screening test that bypasses the assessment of core competencies ceases to be a measure of merit and becomes an arbitrary mechanism of elimination," the bench observed.

Citing the Supreme Court's judgments in Mandeep Singh v. State of Punjab (2025) and Tej Prakash Pathak v. Rajasthan High Court (2024), the court held that sudden changes in recruitment patterns without valid justification violate the principles of fairness under Article 14.

The judge also noted that the HPSC's justification-that over 27,500 candidates had applied and conducting a legal test would be logistically difficult-was unacceptable.

“Administrative convenience cannot override constitutional guarantees. Opportunity cannot be a mirage; it must be real, accessible, and meaningful,” Justice Moudgil remarked.

He further emphasized that by restricting the next stage to only four times the number of posts (about 1,020 candidates), the HPSC had "denied thousands a fair chance to be considered."

Non-Compliance with Statutory Norms

The court found that HPSC failed to consult the State Government as required under Article 320(3)(b) of the Constitution and Clauses 41 and 42 of the Haryana Public Service Commission (Limitation of Functions) Regulations, 1973) before altering the recruitment pattern.

Such consultation, the judge said, is not a formality but a constitutional mandate designed to ensure transparency and consistency in recruitment principles.

"The Commission, under the guise of autonomy, cannot bypass its constitutional obligation by making unilateral changes," the bench warned.

Decision

In its concluding paragraphs, the High Court struck down the announcement dated August 8, 2025, and directed the HPSC to reframe the screening test pattern in line with legal requirements and constitutional fairness.

"To conduct a screening test that excludes legal knowledge for a post rooted in legal expertise is not only irrational but constitutionally untenable," Justice Moudgil declared.

The court ordered the Commission to design a new, law-centric syllabus for the ADA exam and to ensure that every eligible candidate gets an equal opportunity to compete on merit.

With this ruling, the long-awaited ADA recruitment process in Haryana will have to be restarted-this time, under judicially approved parameters.

Case Title:- Lakhan Singh & Others vs State of Haryana & Others

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