Can Experience Of Working At 'Punjab National Bank' Be Counted As 'Govt Office' Experience? Allahabad High Court Answers
In a case concerning eligibility for the post of Registrar (Higher Education), Court holds that PNB experience does not satisfy the 'government office' experience requirement under the specific recruitment advertisement.
The Allahabad High Court has observed that experience acquired while working in Punjab National Bank (PNB) cannot be counted as experience in a "government office" for the purpose of the specific eligibility condition prescribed in an advertisement for the post of Registrar, Higher Education Department, Government of UP.
A bench of Justice Dinesh Pathak was hearing a writ petition filed by Satya Prakash, whose candidature for the post of Registrar (Higher Education) had been rejected on the ground that his experience did not meet the prescribed eligibility criteria.
The primary question before the HC was as to whether the petitioner's experience in PNB falls within the expression "government office" employed in Clause A(2) under the head "Academic Qualification" in the advertisement dated October 17, 2024.
For context, the Advertisement for the Registrar post required candidates to have 15 years' experience at the administrative and supervisory level in a university, "government office" or institution of higher education, or 15 years' teaching experience in a college or university.
The petitioner claimed to have more than 18 years of experience and argued that PNB falls within the expression 'State' under Article 12 of the Constitution and should therefore be treated as a government office.
It was also argued that the expression "government office" had not been defined in the advertisement and that employees of nationalized banks fall within the definition of "public servant" under Section 21 of the Indian Penal Code.
The petitioner relied, among other things, upon judgments concerning the status of PNB under Article 12 and the status of employees of nationalized banks.
The High Court, however, rejected the contention that PNB's status under Article 12 was sufficient to bring the bank within the meaning of the expression "government office" used in the recruitment advertisement.
The Court observed thus:
"The mere inclusion of an entity within the expression 'State' under Article 12 of the Constitution does not, by itself, establish that such entity constitutes a 'government office' for the purpose of the specific eligibility condition prescribed in the advertisement".
The Bench further distinguished between the different legal expressions relied upon by the petitioner.
It observed that 'State' under Article 12 and "public servant" under Section 21 IPC operate within their respective statutory and constitutional contexts, and that their applicability cannot, without further examination, be equated with the expression "government office" employed in the advertisement dated October 17, 2024.
The Court further stated thus:
"Nothing has been brought to the notice of this Court to establish that the Punjab National Bank is a government office and that the employees of the Punjab National Bank are governed under Article 311 of the Constitution of India".
The Court also took note of an earlier Coordinate Bench judgment in Geeta Chandra v. State of UP 2026, concerning experience acquired in a nationalized bank.
In that matter, the Coordinate Bench had rejected claims seeking to count experience acquired from Bank of Baroda and Uttar Pradesh Gramin Bank for the relevant eligibility requirement.
The order is presently under challenge in special appeals which are pending consideration. However, the High Court noted that no interim order had been brought to its notice in those appeals.
Therefore, the pendency of the special appeals, by itself, did not warrant reopening the issue in the present proceedings, the Court said.
The Court also considered the judgments relied upon by the petitioner to establish that PNB constitutes a "government office".
It held that those judgments did not establish, in the context of the specific eligibility condition prescribed in the advertisement, that experience acquired in PNB necessarily falls within the expression "government office".
The Bench accordingly held:
"This Court is not persuaded to accept the petitioner's contention that the experience acquired in Punjab National Bank satisfies the requirement under clause A(2) of the academic qualifications prescribed in the advertisement".
In view of its findings, the Court declined to interfere with the notification dated September 11, 2026, whereby Satya Prakash's candidature for the post had been rejected
The writ petition was consequently dismissed as "misconceived and devoid of merit".
Case title - Satya Prakash vs. State Of U.P. And 2 Others 2026 LiveLaw (AB) 754
Case Citation: 2026 LiveLaw (AB) 754