Introduction:

In a landmark judgment delivered on July 14, 2025, the Supreme Court of India set aside the recruitment of 1,091 assistant professors and 67 librarians by the Punjab Government, ruling the selection process as arbitrary, politically motivated, and in clear violation of binding University Grants Commission (UGC) regulations. The case titled Mandeep Singh and Others v. State of Punjab and Others [2025 LiveLaw (SC) 701] arose from an appeal against a judgment by the division bench of the Punjab and Haryana High Court which had overturned a single-judge bench decision that had quashed the entire recruitment. The apex court, comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran, emphasized that since the State of Punjab had explicitly adopted the UGC (Minimum Qualifications for Appointment of Teachers and Other Academic Staff in Universities and Colleges and Measures for the Maintenance of Standards in Higher Education) Regulations, 2010, those regulations became binding in nature and were not optional. The Court also noted that these appointments, made just ahead of the 2022 assembly elections, appeared to be influenced by narrow political interests rather than educational merit or procedural propriety. In examining the legal basis for the challenge, the Court reiterated that UGC Regulations framed under the UGC Act—which is derived from Entry 66 of List I of the Seventh Schedule to the Constitution—override any state regulations on education framed under Entry 25 of the Concurrent List. Since Entry 25 is subject to Entry 66, Parliament’s law, and subordinate legislations made thereunder, prevail over state laws. The Court stressed that the 2010 UGC Regulations, adopted by the Punjab Government through a government order dated July 30, 2013, remained enforceable even after the 2010 Regulations were replaced by UGC’s 2018 Regulations, simply because Punjab had not adopted the latter. A significant factor in the Court’s decision was the glaring procedural irregularities in the recruitment process. The Court found it wholly unacceptable that the time-tested, rigorous selection process prescribed by the UGC was substituted with a simplified multiple-choice questions-based written test. This sudden and unexplained change, coupled with the elimination of the State Public Service Commission from the process, was deemed a clear departure from constitutional norms of fairness, reasonableness, and transparency.

Arguments:

Senior Advocates Nidhesh Gupta, Raju Ramachandran, Preetesh Kapur, and Rekha Palli represented the appellants who challenged the appointments, while Senior Advocates Kapil Sibal, Rakesh Dwivedi, and PS Patwalia appeared for private respondents who defended the recruitments. Addl Advocate General Shadan Farasat argued on behalf of the State of Punjab. The State contended that the UGC Regulations were advisory and not mandatory.

Judgement:

However, the Supreme Court outright rejected this argument, citing the 2022 precedent in Gambhirdan K. Gadhvi v. State of Gujarat [(2022) 5 SCC 179], which confirmed the binding nature of UGC regulations on both state and central universities. The apex court expressed serious concern over the State’s disregard for its own adopted norms and procedures. It noted that eliminating oral interviews (viva-voce) and replacing academic and research credentials with a mere objective-type test undermined the very quality and integrity of higher education. The judgment made it clear that such a method of recruitment fails to satisfy the test of reasonableness under Article 14 of the Constitution. It reaffirmed that any arbitrary or unreasoned action by the State is constitutionally impermissible, especially when it compromises merit and fair opportunity in public employment. Furthermore, the bench pointed out the timing of the appointments—just months before the state elections in February 2022—as an indication that the recruitment was politically motivated. The government’s attempts to bypass established mechanisms such as the State Public Service Commission reinforced the conclusion that the selection process was designed to serve short-term political interests rather than the long-term interests of educational institutions or public service. The Court found that the division bench of the Punjab and Haryana High Court erred in setting aside the well-reasoned judgment of the single-judge bench. The latter had correctly identified the arbitrariness and illegality in the process and quashed the appointments accordingly. The Supreme Court thus restored the single-judge decision and struck down the entire selection process. The Court’s ruling also underscores the legal sanctity of regulatory bodies like the UGC in ensuring quality and standardization in Indian higher education. By enforcing compliance with UGC regulations, the Court reaffirmed that states cannot pick and choose from central regulations at their convenience, especially after formally adopting them. It emphasized that public appointments, particularly in education, must be carried out in strict conformity with established statutory norms, not through processes that dilute merit or fairness. In a constitutional democracy, the recruitment of educators—who shape future generations—must not be subjected to ad-hocism or politically expedient decision-making. The Court’s scathing observations on the “total arbitrariness” in the Punjab recruitment drive send a clear message to all states about the perils of undermining institutional integrity. With this decision, the Supreme Court has drawn a clear line in the sand on the question of education policy implementation and governance. The verdict serves as a precedent not only in upholding the supremacy of UGC regulations but also as a warning against any state attempt to compromise academic excellence and procedural fairness for political expediency.