1. Recruitment for Junior Engineer (Electrical) — Dispute over whether a Diploma in Electrical and Electronics Engineering is equivalent to a Diploma in Electrical Engineering. (Para 2 , 3 )
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2025 Supreme(SC) 375
SUPREME COURT OF INDIA
PAMIDIGHANTAM SRI NARASIMHA, MANOJ MISRA, JJ.
Sajid Khan – Appellant
Versus
L. Rahmathullah and Others – Respondents
Civil Appeal Nos. 17308, 17309, 17310, 17311 of 2017
Decided On : 20-02-2025
Advocates appeared:
For the Appellant(s) : Mr. Sanand Ramakrishnan, AOR Mr. C. K. Sasi, AOR Ms. Meena K Poulose, Adv. Mr. Manu Krishnan G, AOR
For the Respondent(s): Mr. Sanand Ramakrishnan, AOR Mr. Amarjit Singh Bedi, Adv. Ms. Surekha Raman, Adv. Mr. Shreyash Kumar, Adv. Mr. Harshit Singh, Adv. Mr. Imlikaba Jamir, Adv. Mr. Yashwant Sanjenbam, Adv. Mr. Sidharth Nair, Adv. M/S. K J John And Co, AOR Mr. Manu Krishnan G, AOR Mr. C. K. Sasi, AOR
For the Appellant(s) : Mr. Sanand Ramakrishnan, AOR Mr. C. K. Sasi, AOR Ms. Meena K Poulose, Adv. Mr. Manu Krishnan G, AOR
For the Respondent(s): Mr. Sanand Ramakrishnan, AOR Mr. Amarjit Singh Bedi, Adv. Ms. Surekha Raman, Adv. Mr. Shreyash Kumar, Adv. Mr. Harshit Singh, Adv. Mr. Imlikaba Jamir, Adv. Mr. Yashwant Sanjenbam, Adv. Mr. Sidharth Nair, Adv. M/S. K J John And Co, AOR Mr. Manu Krishnan G, AOR Mr. C. K. Sasi, AOR
The court affirmed that the employer determines qualification equivalence, emphasizing judicial restraint in recruitment matters.
Headnote:(A) Recruitment Rules - Lakshadweep Electricity Department (Group C and D Technical Posts) Recruitment Rules, 2002 - Qualifications for Junior Engineer (Electrical) - Court held that the qualifications of the appellants, Diploma in Electrical and Electronics Engineering, are equivalent to the required qualifications specified in the recruitment notification. The High Court's decision to uphold the CAT's ruling that the appellants lacked equivalent qualifications was set aside. (Paras 1, 6, 24)
(B) Judicial Review - The court emphasized that it is not the function of the court to determine equivalence of qualifications; this is the prerogative of the employer. The court must exercise restraint in matters of recruitment qualifications. (Paras 20, 22)
Facts of the case:
The appellants, Diploma-holders in Electrical and Electronics Engineering, were selected for the post of Junior Engineer (Electrical) in Lakshadweep, but their selection was challenged by respondents who claimed they lacked the required qualifications. (Paras 2-4)
Findings of Court:
The court found that the recruiting authority had treated the appellants' qualifications as equivalent and had not objected to their diplomas. The High Court's technical view was deemed inappropriate. (Paras 18, 24)
Issues: The main issues were whether the appellants' qualifications were equivalent to those specified in the recruitment notification and the extent of judicial review in recruitment matters. (Paras 1, 6)
Ratio Decidendi: The court ruled that the employer is the best judge of qualifications and that the qualifications must be interpreted reasonably, emphasizing the need for judicial restraint in recruitment matters. (Paras 20, 22)
Result: Appeals allowed.
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2. Appellants claim syllabus similarity and employer's informed decision — Respondents argue for strict adherence to advertisement qualifications in the absence of formal equivalence rules. (Para 9 , 10 , 11 , 12 )
3. The employer sought and received technical clarification on equivalence; the appointing authority is the best judge of candidate suitability and qualification equivalence. (Para 14 , 15 , 17 , 18 , 19 , 20 , 21 , 22 )
4. Determining equivalence of qualifications is the prerogative of the employer; courts should exercise restraint and avoid technical interpretations that defeat the recruitment's essential spirit. (Para 18 , 20 , 21 , 23 )
5. Appeals allowed — High Court and CAT orders set aside — Appointments of candidates with equivalent qualifications restored. (Para 1 , 24 )
6. Who is the competent authority to determine the equivalence of educational qualifications for recruitment?
The recruiting agency or employer is the best judge and has the prerogative to decide if a candidate's qualifications are equivalent to the prescribed standards to fulfill the job's objectives. (Para 18 , 19 , 20 , 21 )
7. To what extent can courts interfere in the employer's decision regarding qualification equivalence?
Courts must exercise restraint and generally cannot sit in the chair of the appointing authority. Interference is only warranted if the decision is illegal, arbitrary, or based on glaring differences. (Para 18 , 20 , 21 , 22 )
8. How should recruitment conditions and qualifications be interpreted by the courts?
Terms and conditions of service should be construed reasonably. A strictly technical view that defeats the essential spirit and intent of the recruitment rules should be avoided. (Para 23 )
JUDGMENT :
PAMIDIGHANTAM SRI NARASIMHA, J.
1. We are yet again seized with the common question in recruitment jurisprudence, whether the appellants' qualifications for the post in question meet the standard prescribed in the recruitment notification. This issue is not novel, and this Court has established clear guidelines for judicial review and restraint in determining equivalency. Following these principles, having carefully examined the decision of the employer (U.T. of Lakshadweep) to recognize the appellants' qualifications as equivalent, we found it to be both justifiable and reasonable. Having considered the governing recruitment rules, submissions of the learned counsel and relevant precedents, we allow the appeal. Consequently, we set aside the High Court's decision, which had held that the appellants lacked equivalent qualifications and resulted in the termination of their appointments.
2. Facts: The brief facts leading to this appeal are as follows:
The Union Territory of Lakshadweep, Department of Electricity had issued an advertisement for recruitment to the post of Junior Engineer (Electrical), a Group ‘C’ post. The required qualification was specified to be a Degree in Electrical Engineering from a recognized university, or a Diploma in Electrical Engineering from a recognized institution with two years of experience in any of the fields specified under the relevant recruitment rules.
3. The appellants are all Diploma-holders in Electrical and Electronics Engineering, whereas the respondents hold a Diploma in Electrical Engineering. The appellants and the respondents had participated in the selection process. Pursuant to the recruitment process, the authority published a select list on 03.09.2008 as per which the appellants were declared selected.
4. Aggrieved, the respondents, whose names did not figure in the Select List, filed Original Applications1 [Original Application Nos. 91 of 2009, 554 of 2008, and 638 of 2008] before the Central Administrative Tribunal2 [Hereinafter referred to as ‘CAT’] contending that the appellants held a degree other than the ones specified in the advertisement, and as such, not qualified to be appointed to the post.
5. CAT accepted the said contention and by the common order dated 27.01.2010 allowed the original applications and set aside the appellant’s selection. It relied on the text of the advertisement, and held that unstated qualifications cannot be read as a part of those which are specified.
6. Hence, the appellants filed writ petitions3 [Writ Petition Nos. 15398 of 2010, 6014 of 2010, 14891 of 2010 and OP (CAT) No. 1305 of 2010] before the High Court challenging the CAT’s decision. The Division Bench of the High Court, by the order impugned before us, dismissed the writ petitions and upheld the decision of the CAT. The High Court was of the view that (i) the advertisement was clear in its requirement, and that the appellants did not possess what was required; (ii) the relevant recruitment rules, namely the Lakshadweep Electricity Dept. (Group C and D Technical Posts) Recruitment Rules, 2002, did not provide for any equivalence between Diplomas in Electrical Engineering and Diplomas in Electrical and Electronics Engineering; (iii) the Lakshadweep Administration had not issued any official instruction granting such equivalence and (iv) candidates figuring in the ranked select-list have no indefeasible right to selection.
7. In this view of the matter, the High Court directed that the select list be recast by only including candidates who possessed the exact qualification as prescribed by the advertisement, and the eligible candidates from the fresh list shall replace the appellants. The appellants in Civil Appeal Nos. 17308/2017, 17310/2017, 17309/2017 and 17311/2017 are candidates whose name figured in the select list published by the recruiting authority. Respondent nos. 6-10 in C.A. No. 17308/2017, respondent nos. 6-10 in C.A. No. 17310/2017, respondent nos. 4-6 in C.A. No. 17309
