Academic Qualification For Determining Eligibility Must Be Judged By Curriculum And Purpose, Not Nomenclature Of Degree: Supreme Court
The Apex Court explained that where the prescribed qualification is fulfilled in substance, insistence only on the title of the degree would elevate form over substance.
The Supreme Court has held that eligibility conditions in a recruitment advertisement must be applied in a reasonable and purposive manner by assessing the curriculum and academic content studied by the candidate rather than mechanically depending upon the title of the degree.
The Court was hearing an appeal against the termination of the appellant from his contractual role as Monitoring and Evaluation Consultant, on the ground that he lacked the prescribed qualification, solely because his postgraduate degree did not expressly bear the title “Statistics,” though Statistics was studied by him as a principal subject.
A Division Bench comprising Justice Sanjay Karol and Justice Vipul M. Pancholi observed that “insisting solely on the title of the degree, without considering the actual curriculum, amounts to elevating form over substance”, while underscoring that “the law does not compel such an interpretation.”
Advocates Siddharth R. Gupta and Pashupathi Nath Razdan represented the appellants and the respondents, respectively.
Background
The recruitment advertisement required a “Postgraduate degree in Statistics from a Government recognised University with at least 60% marks or equivalent grade.” The appellant had completed M.Com with Business Statistics and Indian Economic Statistics as his principal subjects, and after proper verification, he was appointed to the post on a contractual basis.
Within a year, a departmental committee concluded that the appellant did not possess the prescribed academic qualification solely because the degree title did not expressly mention Statistics. His services were first terminated in 2013, and though the High Court remanded the matter for reconsideration, termination orders were again issued in 2018 and 2020.
During the process, the University, from which the appellant had completed his degree, certified that Statistics was a major component of the appellant’s postgraduate curriculum. The relevant Department also recorded its opinion supporting the continuation of his service.
However, the authorities persisted in rejecting his eligibility based entirely on nomenclature, and the High Court ultimately upheld the view of the administration, leading to the present appeal.
Court’s Observation
The Supreme Court examined the recruitment requirement and held that the appellant was not seeking equivalence of his degree with another qualification but was asserting that he fulfilled the very qualification prescribed in the advertisement.
The Court noted that it is undisputed that no Government university in Madhya Pradesh offers a postgraduate programme titled “M.Com (Statistics)” or any postgraduate degree exclusively named “Statistics.” In this context, the provision must be interpreted in the manner intended, to ensure candidates possess knowledge and training in Statistics, irrespective of degree nomenclature.
The Bench further held that while Courts ordinarily refrain from evaluating academic equivalence in service matters, judicial review becomes necessary when decisions of the employer disregard relevant academic material or misapply standards, resulting in arbitrariness. Here, the authorities had failed to consider the university certification, which expressly confirmed that Statistics was a primary subject in the appellant’s programme.
Discussing procedural flaws, the Court found that the committee report relied upon by the Department was prepared without giving the appellant any opportunity of hearing. The findings in that report were also found to be contradicted by academic records later verified by a competent institutional authority. Rejecting the appellant’s eligibility in these circumstances was held to be unfair, unreasonable, and violative of Articles 14 and 16 of the Constitution.
The Court concluded that insisting only on nomenclature is impermissible when the academic purpose of the qualification is demonstrably satisfied.
Conclusion
The Supreme Court set aside the impugned judgments and restored the appellant to his position within four weeks, subject to there being no other disqualification.
Cause Title: Laxmikant Sharma v. State of Madhya Pradesh & Others (Neutral Citation: 2025 INSC 1385)
Appearances
Appellant: Advocates Siddharth R. Gupta, Mrigank Prabhakar, U.N. Pandey, Aman Agarwal, Uddaish Palya and others
Respondents: Advocates Pashupathi Nath Razdan, Sarthak Raizada, Maitreyee Jagat Joshi, Astik Gupta, Akanksha Tomar