The Punjab and Haryana High Court has held that a candidate who attached an expired Backward Class-A (BCA) certificate with her application for a teaching post cannot be treated as eligible on the strength of a fresh certificate obtained after the last date for applying.

A Division Bench of Justice Harsimran Singh Sethi and Justice Minderjeet Yadav dismissed a Letters Patent Appeal against a Single Judge's order upholding the cancellation of the appellant's candidature for the post of Primary Teacher (PRT), Mewat Cadre, in the BCA category.

"Merely because subsequent to the last date, another certificate was issued to the appellant, the same will not ratify her application form to be treated as an eligible candidate," the Court said.

Advertisement was invited applications for 1,456 PRT posts in the Mewat Cadre, with the last date of submission being August 21, 2024. BCA candidates were required to attach a valid certificate in terms of the State's instructions dated March 22, 2022, failing which their candidature would be cancelled.

The appellant attached a BCA certificate issued in January 2024 and was allowed to compete provisionally. At the scrutiny stage, it was found that under the 2022 instructions, certificates involving income or creamy layer criteria are valid only till March 31 of the financial year of issue. Her certificate had therefore lapsed on March 31, 2024, well before the last date for applying, and she was not allowed to proceed in the BCA category. Her writ petition was dismissed by the Single Judge on August 17, 2026.

Senior counsel for the appellant argued that by the time scrutiny took place in 2025, she had obtained a valid certificate, and since only the fact of eligibility needed to be demonstrated, it should have been considered. It was also submitted that less meritorious candidates had been appointed and three BCA posts were still lying vacant.

The State countered that the terms of the advertisement are sacrosanct, that Clause 11 mandated cancellation where no valid certificate was attached, and that the later certificate only established eligibility for a subsequent period, not the period relevant to the advertisement.

Relying on the Supreme Court's decision in Mohit Kumar v. State of Uttar Pradesh, the Bench reiterated that the terms of an advertisement must be strictly followed by all candidates, and that once recruitment is set in motion, there cannot be different yardsticks for different aspirants. The Court also referred to a Coordinate Bench ruling in Haryana Public Service Commission v. Pardeep Kumar (LPA-1397-2025), which relied on Dolly Chhanda v. Chairman, JEE to hold that a candidate must possess the eligibility on the last date fixed, and noted that an SLP against that ruling had since been dismissed by the Supreme Court.

Referring the 2022 instructions, the Court held that the January 2024 certificate "lost its sanctity" on March 31, 2024, and attaching it to an application submitted months later could not be accepted. It further noted that Clause 12.12 of the advertisement barred consideration of any document not uploaded with the application form.

On the vacant posts, the Bench accepted the State's submission that only candidates who competed in conformity with the advertisement could be considered. It observed that the appellant's participation was provisional, subject to scrutiny, which she had failed:

"On the mere aspect that the posts are lying vacant, appellant's candidature cannot be considered by ignoring the claim of the candidate, who competed in conformity with the application."

Finding no ground to interfere, the Court dismissed the appeal.

Case Title: Munisha v. State of Haryana and Others

Appearance: Mr. Sunil Kumar Nehra, Senior Advocate, assisted by Mr. Rahil Mahajan, Advocate for the appellant.

Mr. Nitin Kaushal, Additional Advocate General, Haryana.

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