Calculation of Salary Under 7th Central Pay Commission(7th Pay Matrix)

Introduction

The Supreme Court of India delivered a landmark judgment on July 14, 2025, in the case of Mandeep Singh & Ors. v. State of Punjab & Ors. [1], fundamentally reaffirming the supremacy of University Grants Commission (UGC) regulations over state-specific recruitment procedures in higher education. The judgment, delivered by a bench comprising Justice Sudhanshu Dhulia and Justice K. Vinod Chandran, quashed the appointments of 1,091 Assistant Professors and 67 Librarians made by the Punjab Government in October 2021, marking a significant victory for academic integrity and constitutional governance. In a moment that will shape recruitment practices across the country, the Supreme Court upholds UGC regulations as binding on states that have adopted them, effectively resolving tensions between national standards and regional autonomy in academic hiring.

This decision represents a crucial intervention in the ongoing tension between federal educational standards and state autonomy in recruitment processes. The court’s ruling not only addresses the immediate concerns regarding the Punjab appointments but also establishes important precedents for the future conduct of academic recruitment across all states in India. The judgment emphasizes that once a state adopts UGC regulations, it becomes constitutionally bound to follow them, regardless of any conflicting state-specific procedures.

Constitutional and Legal Framework

Federal Structure and Educational Governance

The Indian Constitution’s Seventh Schedule delineates the distribution of powers between the Union and State governments through three lists: Union List, State List, and Concurrent List. Education finds its place in the Concurrent List as Entry 25, which grants both Union and State governments the power to legislate on educational matters. However, Entry 66 of the Union List specifically empowers the Union government to coordinate and determine standards in institutions of higher education, including research and technical institutions.

This constitutional framework creates a hierarchy where Union legislation on educational standards takes precedence over state laws when there is a conflict. The Supreme Court has consistently held that coordination of educational standards at the national level is essential for maintaining uniformity and quality in higher education across the country.

UGC’s Statutory Authority

The University Grants Commission was established under the University Grants Commission Act, 1956 [2], as a statutory body responsible for the coordination, determination, and maintenance of standards of university education in India. The UGC’s authority extends to all universities and colleges affiliated with universities, making it the apex body for higher education regulation.

The UGC Regulations on Minimum Qualifications for Appointment of Teachers and Other Academic Staff in Universities and Colleges and Measures for the Maintenance of Standards in Higher Education, 2018 [3], form the cornerstone of academic recruitment in India. These regulations establish comprehensive guidelines for the appointment of faculty members, including detailed criteria for academic qualifications, research experience, and selection procedures.

Article 14 and Equal Protection

Article 14 of the Constitution guarantees equality before the law and equal protection of laws to all persons within the territory of India. This fundamental right encompasses the principle of reasonableness in state action, requiring that government decisions be based on relevant considerations and follow established procedures. The Supreme Court has consistently held that arbitrary state action, particularly in matters of public employment, violates Article 14.

The doctrine of equality under Article 14 requires that similarly situated individuals be treated equally, and any classification must be reasonable and have a nexus with the object sought to be achieved. In the context of public employment, this means that recruitment procedures must be fair, transparent, and based on merit.

Case Background and Factual Matrix

The Punjab Recruitment Process

The controversy surrounding the Punjab appointments began when the state government decided to recruit 1,158 faculty members for its government degree colleges through an expedited process that deliberately bypassed established UGC norms. The recruitment was conducted through a Departmental Selection Committee rather than the Punjab Public Service Commission (PPSC), which is the constitutional body mandated to conduct such recruitments under the Punjab Educational Services Class II Rules, 1976.

The state government replaced the comprehensive UGC selection procedure, which includes evaluation of Academic Performance Index (API), teaching experience, research contributions, and structured interviews, with a single written test consisting of multiple-choice questions. This dramatic deviation from established norms was justified by the state on grounds of urgency and the need to fill vacant positions in newly established colleges.

Timeline and Political Context

The recruitment process was initiated with unprecedented speed, with the entire exercise completed within two months, including a 45-day application period. The timing of this recruitment, coming just before the 2022 State Assembly elections, raised serious questions about the political motivations behind the decision. The petitioners argued that the hasty nature of the recruitment was designed to benefit certain candidates and constituencies in the run-up to the elections.

The state government’s decision to abandon the established UGC procedure was made without any prior consultation with stakeholders, academic bodies, or the PPSC. This unilateral decision-making process violated principles of administrative fairness and transparency that are fundamental to constitutional governance.

Impact on Academic Community

The Punjab government’s decision affected not only the candidates who were appointed through the irregular process but also those who had been preparing for recruitment under the established UGC norms. The deviation from standard procedures created uncertainty in the academic community and undermined confidence in the merit-based selection process.

The irregular appointments also had broader implications for the quality of education in Punjab’s government colleges, as the abbreviated selection process failed to adequately assess the teaching capabilities and research potential of candidates. This raised concerns about the long-term impact on educational standards in the state.

Supreme Court’s Analysis and Reasoning

Supremacy of UGC Regulations

The Supreme Court’s analysis began with a thorough examination of the constitutional framework governing education and the specific powers of the UGC. The court reaffirmed the principle established in the Adhyaman Educational Institute case [4] that UGC regulations have primacy over conflicting state regulations due to the Union’s power under Entry 66 of List I, which overrides Entry 25 of List III in the Seventh Schedule.

In this context, the Supreme Court upholds UGC regulations as constitutionally binding, underscoring that the UGC’s role in coordinating and determining standards in higher education institutions is not merely advisory but carries the force of law. Once a state adopts UGC regulations, it becomes constitutionally obligated to follow them in letter and spirit. The court noted that the Punjab government had officially adopted the UGC Regulations 2018, making compliance mandatory rather than optional.

Analysis of Selection Procedures

The Supreme Court conducted a detailed analysis of the UGC’s prescribed selection procedures for Assistant Professors and Librarians. The UGC Regulations 2018 establish a comprehensive framework that includes multiple components: academic record evaluation (50% weightage), domain knowledge and teaching skills assessment (30% weightage), and interview performance (20% weightage). This multi-faceted approach ensures that candidates are evaluated holistically rather than on the basis of a single parameter.

The court noted that the Academic Performance Index (API) system, which forms a crucial component of the UGC selection process, is designed to evaluate candidates’ research contributions, teaching experience, and academic achievements in a standardized manner. This system ensures that appointments are based on merit and academic excellence rather than subjective considerations.

Violation of Natural Justice

The Supreme Court found that the Punjab government’s decision to abandon the established selection procedure without providing adequate justification violated principles of natural justice. The court emphasized that the sudden change in procedure, implemented without prior notice or consultation, denied candidates the opportunity to prepare adequately for the selection process under the new system.

The court also noted that the elimination of the interview component, which allows for direct assessment of candidates’ teaching abilities and subject knowledge, fundamentally altered the nature of the selection process. This change was made without any reasoned justification and appeared to be motivated by considerations of convenience rather than merit.

Article 14 Violations

The Supreme Court held that the Punjab government’s recruitment process violated Article 14 of the Constitution in multiple ways. First, the arbitrary nature of the decision to change the selection procedure without adequate justification constituted unreasonable state action. Second, the hasty implementation of the new procedure denied equal treatment to candidates who had been preparing under the established system.

The court referenced several precedents, including Ramana Dayaram Shetty v. International Airport Authority of India [5], to establish that state action must be reasonable, non-arbitrary, and based on relevant considerations. The Punjab government’s decision failed to meet these constitutional standards.

Consultation with Public Service Commission

The Supreme Court also addressed the violation of Article 320(3) of the Constitution, which mandates consultation with the Public Service Commission in matters of recruitment to public services. The court noted that the Punjab government’s decision to bypass the PPSC and conduct recruitment through a Departmental Selection Committee violated this constitutional requirement.

Article 320(3) requires that the Public Service Commission be consulted on all matters relating to methods of recruitment to civil services and civil posts. This consultation is not merely procedural but serves the important function of ensuring that recruitment processes are conducted fairly and transparently.

Judicial Precedents and Legal Principles

Adhyaman Educational Institute Precedent

The Supreme Court, while reaffirming its position, extensively relied on the Adhyaman Educational Institute (P) Ltd. v. Union of India [4] case, which established the fundamental principle that UGC regulations are binding on all educational institutions, including state-run institutions. This precedent clarified that the Supreme Court upholds the primacy of UGC regulations and that state laws, including delegated legislation, cannot be inconsistent with the standards specified by the UGC.

The Adhyaman judgment recognized the UGC’s role as the national coordinating body for higher education and established that uniformity in educational standards is essential for maintaining quality across the country. The court noted that allowing states to deviate from UGC norms would undermine the fundamental purpose of having a national coordinating body.

Reasonableness and State Action

The court referenced the landmark judgment in Sivanandan C.T. v. High Court of Kerala [6], which established that state orders must follow principles of consistency, foreseeability, and transparency. The Punjab recruitment process failed to meet these standards, as it was implemented hastily without adequate consultation or justification.

The court also cited Zenit Mataplast v. State of Maharashtra [7] to establish that arbitrary and precipitate state action violates Article 14. The Punjab government’s decision to change the recruitment procedure at short notice without adequate justification constituted such arbitrary action.

Legitimate Expectations Doctrine

The Supreme Court applied the doctrine of legitimate expectations, which holds that when a government creates expectations through its policies and procedures, it cannot arbitrarily change those expectations without adequate justification. The Punjab government had adopted the UGC Regulations 2018, creating legitimate expectations among potential candidates that recruitment would be conducted according to those standards.

The court noted that candidates who had been preparing for recruitment under the UGC norms had legitimate expectations that the established procedure would be followed. The arbitrary change in procedure violated these expectations and constituted unfair treatment.

Regulatory Framework and Implementation Challenges

UGC Regulations 2018: Comprehensive Framework

The UGC Regulations on Minimum Qualifications for Appointment of Teachers and Other Academic Staff in Universities and Colleges, 2018 [3], represent a comprehensive framework designed to ensure quality and uniformity in academic appointments across India. These regulations establish detailed criteria for different academic positions, including minimum educational qualifications, research experience requirements, and standardized selection procedures.

The regulations require that candidates for Assistant Professor positions possess a Master’s degree with at least 55% marks and qualify in the National Eligibility Test (NET) or State Eligibility Test (SET). Additionally, the regulations establish the Academic Performance Index (API) system, which quantifies candidates’ research contributions, teaching experience, and academic achievements.

Implementation Challenges in State Systems

The implementation of UGC regulations in state educational systems faces several challenges, including resource constraints, administrative capacity limitations, and resistance to change. Many states have established their own procedures and systems over the years, creating institutional inertia that makes it difficult to adopt new standards and procedures.

The Punjab case highlights the need for better coordination between the UGC and state governments to ensure smooth implementation of national standards. This includes providing adequate support for capacity building, training of personnel, and development of necessary infrastructure.

Role of Public Service Commissions

Public Service Commissions play a crucial role in ensuring fair and transparent recruitment processes in state government services. Article 320 of the Constitution establishes the constitutional mandate for Public Service Commissions and requires their consultation in matters of recruitment. The Punjab case demonstrates the importance of maintaining this constitutional requirement and the consequences of bypassing these institutions.

The expertise and experience of Public Service Commissions in conducting fair and transparent recruitment processes make them essential partners in implementing UGC regulations at the state level. Their involvement ensures that recruitment processes meet constitutional standards and maintain public confidence in the merit-based selection system.

Impact on Higher Education Governance

Strengthening Federal Standards

The Supreme Court’s judgment in the Punjab case significantly strengthens the federal framework for higher education governance in India. By reaffirming that the Supreme Court upholds UGC regulations over state-specific procedures, the court has ensured that national standards for academic appointments will be maintained across all states.

This decision is particularly important in the context of India’s federal structure, where the tendency toward state autonomy can sometimes conflict with the need for national coordination in critical areas like education. The judgment establishes clear boundaries and ensures that the UGC’s coordinating role is not undermined by state-specific deviations.

Implications for Academic Quality

The enforcement of UGC regulations has significant implications for academic quality in Indian higher education. The comprehensive selection procedures prescribed by the UGC ensure that appointments are based on merit and academic excellence rather than political considerations or administrative convenience.

The judgment also sends a strong message to state governments that attempts to compromise academic standards for political or administrative reasons will not be tolerated by the courts. This is likely to encourage greater compliance with UGC norms and improve the overall quality of academic appointments.

Protection of Merit-Based Selection

The Supreme Court’s decision provides strong protection for merit-based selection in academic appointments. By striking down the Punjab government’s attempt to replace comprehensive evaluation procedures with a simple written test, the court has reinforced the principle that academic appointments must be based on thorough assessment of candidates’ qualifications and capabilities.

This protection is particularly important in the current context, where there are increasing pressures on academic institutions to compromise on merit for various reasons. The judgment establishes clear judicial backing for maintaining high standards in academic recruitment.

Constitutional Principles and Administrative Law

Separation of Powers and Judicial Review

The Punjab case demonstrates the important role of judicial review in maintaining constitutional governance and preventing administrative overreach. The Supreme Court’s intervention prevented the Punjab government from implementing a recruitment process that violated constitutional principles and statutory requirements.

The judgment also illustrates the delicate balance between respecting state autonomy and ensuring compliance with constitutional requirements. While states have significant autonomy in governance matters, this autonomy cannot be exercised in a manner that violates constitutional principles or statutory obligations.

Procedural Due Process

The court’s emphasis on procedural due process in the Punjab case highlights the importance of following established procedures in administrative decision-making. The requirement that government decisions be based on adequate consultation, proper justification, and compliance with statutory requirements is fundamental to constitutional governance.

The violation of procedural due process in the Punjab case not only affected the specific recruitment process but also undermined public confidence in the fairness and transparency of government decision-making. The court’s intervention helped restore confidence in the system and established important precedents for future cases.

Transparency and Accountability

The Supreme Court’s judgment emphasizes the importance of transparency and accountability in government decision-making. The Punjab government’s decision to change the recruitment procedure without adequate consultation or justification violated these fundamental principles of democratic governance.

The court’s requirement that government decisions be based on reasoned justification and proper consultation serves as an important check on arbitrary exercise of power. This requirement is particularly important in matters of public employment, where fairness and transparency are essential for maintaining public confidence.

Future Implications and Recommendations

Strengthening Coordination Mechanisms

The Punjab case highlights the need for stronger coordination mechanisms between the UGC and state governments to ensure smooth implementation of national standards. This includes regular consultation, capacity building programs, and technical support for states in implementing UGC regulations.

The development of standardized procedures and guidelines for states to follow when implementing UGC regulations would help prevent future conflicts and ensure consistent application of national standards across all states.

Enhancing Compliance Monitoring

The case also demonstrates the need for enhanced monitoring of compliance with UGC regulations. The UGC should establish robust monitoring mechanisms to ensure that states are following prescribed procedures and standards in academic appointments.

Regular audits and reviews of state recruitment processes would help identify potential violations early and allow for corrective action before problems escalate to litigation. This would benefit both the states and the academic community by ensuring consistent application of standards.

Capacity Building for State Institutions

Many states may lack the necessary capacity to implement UGC regulations effectively. The UGC should provide comprehensive support for capacity building, including training programs for state officials, development of necessary infrastructure, and technical assistance in implementing new procedures.

This support would help states comply with UGC regulations more effectively and reduce the likelihood of future conflicts between national standards and state practices.

Conclusion

The Supreme Court’s judgment in Mandeep Singh & Ors. v. State of Punjab & Ors. marks a pivotal moment in the evolution of higher education governance in India. By reinforcing the binding nature of national standards, the ruling affirms that institutions cannot sidestep uniform norms under the guise of administrative autonomy. In effect, the Supreme Court upholds UGC regulations as essential instruments for ensuring transparency, fairness, and academic integrity in recruitment.

The judgment establishes important precedents for the future conduct of academic recruitment across all states and sends a strong message that attempts to compromise academic standards for political or administrative convenience will not be tolerated. The court’s emphasis on procedural due process, transparency, and accountability provides valuable guidance for government decision-making in all areas.

The decision also highlights the important role of judicial review in maintaining constitutional governance and preventing administrative overreach. The court’s intervention in the Punjab case prevented the implementation of a recruitment process that violated constitutional principles and statutory requirements, thereby protecting the interests of both the academic community and the broader public.

Looking forward, the judgment provides a strong foundation for maintaining high standards in academic recruitment and ensuring that the UGC’s coordinating role in higher education is not undermined by state-specific deviations. The emphasis on merit-based selection and compliance with established procedures will contribute to improving the overall quality of higher education in India.

References

[1] Mandeep Singh & Ors. v. State of Punjab & Ors., 2025 INSC 834, Supreme Court of India. 

[2] University Grants Commission Act, 1956, Act No. 3 of 1956, Government of India. Available at: https://www.ugc.gov.in/page/UGC-Act-1956.aspx 

[3] UGC Regulations on Minimum Qualifications for Appointment of Teachers and Other Academic Staff in Universities and Colleges, 2018. Available at: https://www.mgu.ac.in/ugc-regulations-2018-minimum-qualification-for-appointment-of-teachers-and-other-academic-staff-in-universities-and-colleges/ 

[4] Adhyaman Educational Institute (P) Ltd. v. Union of India, (1995) 4 SCC 104, Supreme Court of India. Available at: https://indiankanoon.org/doc/1766147/ 

[5] Ramana Dayaram Shetty v. International Airport Authority of India, (1979) 3 SCC 489, Supreme Court of India. Available at: https://indiankanoon.org/doc/1372677/ 

[6] Sivanandan C.T. v. High Court of Kerala, (2024) 3 SCC 1, Supreme Court of India. Available at: https://www.livelaw.in/supreme-court/supreme-court-judicial-discipline-sivanandan-ct-v-high-court-of-kerala-274486 

 

Authorized by Prapti Bhatt