Punjab & Haryana High Court, Chandigarh
Citation(1992) 4 SCC 118
CourtSupreme Court of India (Constitution Bench)
Date28 July 1992
Year1992
BenchM.N. Venkatachaliah, K. Jayachandra Reddy, S.R. Pandian, P.B. Sawant, S. Mohan JJ.
Acts/ArticlesArticle 14, Article 16, Article 309
CategoryConstitutional Law, Haryana-Specific, Service & Employment Law

Key Principle Established

Government cannot relax age/qualification conditions for individual candidates. Relaxation must be general and not person-specific, otherwise it violates Article 14.

Brief Facts

The State of Haryana relaxed the upper age limit for certain individual candidates seeking recruitment to government posts. Other candidates challenged this individual-specific relaxation as arbitrary and discriminatory.

Ratio Decidendi

The Constitution Bench held:

  • Individual-specific age relaxation violates Article 14 — relaxation must be for an identifiable class, not named individuals
  • Government can prescribe qualifications and conditions, but relaxation must be general and objective
  • Person-specific relaxation is back-door entry into government service
  • Eligibility criteria must be uniformly applied to all candidates

Impact & Significance

A Haryana-origin landmark that governs all recruitment across India. It prevents nepotism in government recruitment through individual-specific relaxation of eligibility criteria. Frequently cited in HPSC recruitment challenges.

Tags & Related Topics

← Previous Judgment Rudra Kumar Sain v. Union of India
Next Judgment → State of Haryana v. Bhajan Lal

Related Judgments

1982

Randhir Singh v. Union of India

(1982) 1 SCC 618

Equal pay for equal work is a constitutional goal derivable from Articles 14, 16, and 39(d) read together.

Read Analysis
2020

Vineeta Sharma v. Rakesh Sharma

(2020) 9 SCC 1

Daughters have equal coparcenary rights by birth under the Hindu Succession (Amendment) Act, 2005 — irrespective of whether the father…

Read Analysis
1996

State of Haryana v. Jasmer Singh

(1996) 11 SCC 77

Contractual employee retained beyond tenure cannot be terminated without following principles of natural justice.

Read Analysis

Disclaimer

This judgment summary is for educational and research purposes. While care has been taken to accurately represent the ratio and findings, for authoritative reference always consult the original judgment text from official sources (SCC Online, AIR, Manupatra, or court websites).

Need Case Law Research or Legal Representation?

22+ years of practice before Punjab & Haryana High Court and Supreme Court of India.

Call: +919915442266 WhatsApp

Need Legal Assistance?

Contact Advocate Ravinder Singh Dhull for expert legal guidance on your matter.