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2025 Supreme(Ori) 351

IN THE HIGH COURT OF ORISSA AT CUTTACK
S.K. SAHOO, SIBO SANKAR MISHRA, JJ.
Satish Ranjan Samantray – Appellant
Versus
Union of India and Others – Respondents
W.P. (C) No. 28663 of 2025
Decided On : 08-12-2025

Advocates:
Advocate Appeared:
For the Appellant : Subhankar Das
For the Respondents: P.K. Parhi, S.K. Samantaray

Judicial review does not extend to determining educational qualifications' equivalence, which is within an administrative purview.

Headnote:(A) Central Administrative Tribunal Act - Dismissal of Original Application - The petitioner challenged the Tribunal's decision denying equivalence of Adeeb-e-Mahir to 10+2 for PA cadre recruitment - Tribunal cited that equivalence is a technical academic matter outside its jurisdiction. (Paras 1, 2, 5, 6)

(B) Equivalence of Qualifications - Judicial review does not extend to deciding qualifications' equivalence, which remains an administrative domain, supported by precedence from higher courts. (Paras 4, 5, 6)

Facts of the case:
The petitioner applied for a position under the sports quota, asserting his Adeeb-e-Mahir certificate's equivalence to a 10+2 qualification. The recruitment was denied based on the government’s determination of its non-equivalence.

Findings of Court:
The court affirmed the Tribunal's decision noting no grounds for reviewing qualifications' equivalency lies in judicial purview.

Issues: The main issues included the acceptability of Adeeb-e-Mahir as equivalent to 10+2 qualification and the authority of the Tribunal in this matter.

Ratio Decidendi: The court held that issues of educational equivalence lie outside its jurisdiction, emphasizing that administrative decisions should be based on stated qualifications and not expanded through judicial review.

Result: Writ petition dismissed.

ORDER : 

1. This matter is taken up through Hybrid arrangement (video conferencing/physical mode).

2. Heard Mr. Subhankar Das, learned counsel for the petitioner and Mr. P.K. Parhi, learned DSGI along with Mr. S.K. Samantaray, learned CGC for the opp. parties.

3. This writ petition has been filed by the petitioner, Satish Ranjan Samantray challenging the order dated 01.05.2025 passed by the learned Central Administrative Tribunal, Cuttack Bench, Cuttack (for short, “Tribunal”) in O.A. No.260/00545 of 2019 in dismissing the O.A. with a Signature Not Verified Digitaly Signed Signed by: SIPUN BEHERA further prayer for a direction to the opp. parties to Designation: Senior Stenographer Reason: Authentication Location: HIGH COURT OF ORISSA, CUTTACK Date: 09-Dec-2025 11:40:47 provide appointment to the petitioner under PA/SA Cadre in accordance with advertisement no.S.Cell/1-RE/2014 under the sports quota for carrom in the interest of justice.

4. The Original Application was filed by the petitioner before the learned Tribunal, wherein prayer was made for a direction to the opp. parties to give appointment to the petitioner against the post of PA cadre under Sundargarh Division.

5. The main ground taken in the Original Application for claiming relief is that in the said advertisement notice for recruitment of sports persons only in PA/SA Cadre, the minimum educational qualification has been prescribed as 10+2 pass. It is stated therein that sports persons who have represented the Country or State in an International or National Competition or represented their Universities in the Inter University tournament conducted by the Inter University Sports Board or represented the State School team in the National Sports/Games conducted by the All India School Games Federation in Hockey/Athletics/Basketball/Cricket/Carrom or awarded National Awards in physical efficiency under the National Physical Efficiency Drive and were within the age limit of 18-27 years can apply for the vacancies, which were 8 in number.

6. Pursuant to such advertisement, the petitioner applied for the said post and the opp. party no.2 vide letter dated 19.01.2015 approved the recruitment of the petitioner for the post of PA Cadre in Odisha Circle under sports quota and was allotted to Sundargarh Division under Carrom discipline.

7. The letter dated 19.01.2015 was received by the petitioner from the Senior Superintendent of Post Offices, Sundargarh Division, Sundargarh to submit some documents and certificates in original for verification in order to facilitate his selection and accordingly, the petitioner submitted the required documents and certificates.

8. It is the case of the petitioner that in the said advertisement, it is prescribed that the educational qualification must be “10+2 pass” and the petitioner had passed Adeeb-e-Mahir from Jamia Urdu Aligarh University which is equivalent to intermediate or 10+2 examination.

9. According to the petitioner, the said qualification i.e. Adeeb-e-Mahir was verified and certified by the Ministry of Home Affairs/Home Ministry (Department of Personnel and Administration Reform) vide office memorandum dated 28th June, 1978 and it has been confirmed by the Jamia Urdu Aligarh University by issuing a letter dated 16.11.2015 to the opp. party no.3 i.e. Senior Superintendent of Post Offices, Sundargarh Division, Sundargarh.

10. The petitioner sought for information regarding the status of his documents verification and equivalence of Adeeb-e-Mahir certificate with 10+2 through RTI, from where he came to know that the opp. party no.1 has taken a decision that Adeeb-e-Mahir certificate course offered by the Jamia Urdu Aligarh University is not equivalent to 10+2 standard for the purpose of employment under Central Government.

11. It is the further case of the petitioner that since the minimum educational qualification required for the post was 10+2 or any equivalent examination, which was awarded by any Board/University and the petitioner has

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