2026 Supreme(Cal) 201

IN THE HIGH COURT AT CALCUTTA [CIRCUIT BENCH AT PORT BLAIR]
SABYASACHI BHATTACHARYYA, SMITA DAS DE, JJ.
The Union Of India And Others - Petitioners 
Versus
Shri Yohannan Sajeevan And Others – Respondents
WP.CT 58 of 2025
Decided On : 24-04-2026

Promotional rules cannot arbitrarily waive mandatory educational qualifications required by national regulatory bodies. Creating a discriminatory classification based on service tenure to bypass legitimate academic standards violates the right to equality under the constitution, and such administrative exemptions are void.

Headnote:(A) Administrative Law - Recruitment Rules - Validity of exemption for promotional eligibility - An administrative provision exempting existing employees from mandatory academic requirements for promotion is discriminatory and void if it contravenes regulatory standards for higher education. Regulations mandate specific degree durations for master’s level entry. Granting relaxation purely based on service tenure creates an arbitrary distinction lacking intelligible differentia, violating the constitutional principle of equality. (Paras 27-31, 39-43, 47, 48-49)

(B) Promotion - Eligibility criteria - An administrative body cannot, through a discretionary exemption, bypass established national academic standards. Educational quality and qualifications for academic leadership positions must remain consistent. Indiscriminate relaxation of these criteria for incumbent staff creates an unfair disadvantage for qualified candidates and undermines the integrity of the selection process. (Paras 45-46, 49)

Facts of the case:
Administrative authorities formulated recruitment rules for promotional posts in schools, incorporating an exception allowing current incumbents to be exempted from mandatory educational qualification requirements. A legal challenge was initiated against this provision, contending that it facilitated the promotion of individuals lacking necessary credentials, thereby contradicting established national regulatory guidelines regarding university degrees and professional qualifications.

Findings of Court:
The court determined that the exemption clause was ultra vires the regulatory guidelines. It found the differentiation between existing staff and future candidates unreasonable and lacking a rational nexus to the objectives of the service rules. The exemption effectively attempted to validate academically insufficient degrees, which undermined educational quality and violated constitutional equality standards.

Issues: Whether the recruitment rules allowing an exemption from mandatory educational qualifications for existing employees were valid, and whether such relaxation violated regulatory guidelines and constitutional equality principles.

Ratio Decidendi: Administrative policies cannot provide exemptions that contravene established national academic benchmarks. Distinguishing between employees based on tenure to permit non-compliance with educational prerequisites creates an unreasonable class that lacks a rational nexus to the stated purpose of the recruitment policy, rendering such provisions unconstitutional.

Result: Petition dismissed; the impugned relaxation clause in the recruitment rules was set aside and directed to be withdrawn.