Judicial Analysis Court Copy Headnote Facts Arguments Court observation

2026 Supreme(Online)(Kar) 20675

THE HIGH COURT OF KARNATAKA
S.R.Krishna Kumar, J
Nagabhushan D. Goudar – Appellant
Versus
Karnataka Power Corporation Limited – Respondent
WP No. 4356 of 2026

Advocates:
For the Appellants/Petitioners: Ashoka T.
For the Respondents: Ajay J. Nandalike, N. K. Ramesh

In a competitive recruitment process, courts cannot relax or alter prescribed eligibility criteria mid-stream to accommodate candidates, nor can they treat higher qualifications or alternative proficiency tests as equivalent to mandatory requirements unless expressly provided by the recruitment rules.

Headnote:(A) Recruitment Process - Eligibility Criteria - Mandatory Language Test - Clause 8 of Notification mandated candidates to study Kannada at SSLC/equivalent level or pass departmental Kannada language test - Petitioner failed to study Kannada at SSLC and erroneously declared compliance in application - Whether higher qualification (PUC) or external certificate (KPSC) can substitute specific mandatory requirement - Held, No. (Paras 9, 10, 11, 12, 16)

(B) Judicial Review - Power of - Scope and Ambit - Courts cannot relax stipulated eligibility criteria or modify recruitment conditions mid-process to accommodate individual candidates, as such actions would violate Article 14 and 16 of the Constitution of India and prejudice other candidates. (Paras 17, 18)

Facts of the case:
Petitioner applied for a post under a 2017 Recruitment Notification which prescribed Kannada language proficiency at the SSLC/CBSE level. Despite not studying Kannada in 10th standard, the petitioner erroneously ticked 'Yes' in the application form, bypassing the departmental language test. Later, seeking to rectify his status by submitting a PUC qualification and a KPSC Kannada certificate, the petitioner approached the High Court after being disqualified during document verification.

Findings of Court:
The Court held that the petitioner, having made a conscious (albeit alleged inadvertent) declaration in his application to circumvent the mandatory test, could not now seek to rewrite the recruitment rules. The prescription of qualifications is a policy matter, and higher qualifications do not automatically equate to prescribed ones unless explicitly permitted by rules.

Issues: Whether the petitioner's study of Kannada at PUC level or clearance of the KPSC language test constitutes sufficient compliance with the mandatory Kannada language proficiency requirement prescribed in the 2017 Notification for SSLC level.

Ratio Decidendi: Where a recruitment notification prescribes specific eligibility qualifications, courts cannot substitute these with higher qualifications or alternate certificates unless the rules specifically provide for such equivalence. Relaxing such conditions for a single candidate mid-process would violate the principles of equality under Articles 14 and 16 of the Constitution of India.

Result: Petition dismissed.

Table of Content
1. failure to meet specific eligibility criteria leads to disqualification in recruitment. (Para 1 , 2 , 3)
2. notifications must be strictly interpreted without substituting higher qualifications. (Para 9 , 10 , 11 , 12)
3. higher qualifications are not equivalent unless rules explicitly state so. (Para 13)
4. estoppel applies to declarations made in applications to circumvent mandatory tests. (Para 15 , 16)
5. rules of recruitment cannot be relaxed for individual candidates mid-process. (Para 17 , 18 , 19 , 20)

THIS W.P. IS FILED UNDER ARTICLES 226 & 227 OF CONSTITUTION OF INDIA PRAYING TO DIRECTING THE RESPONDENTS TO CONSIDER THE REPRESENTATION DATED 06.02.2026 OF THE PETITIONER VIDE ANNEXURE-H AND CONSEQUENTLY CONSIDER PETITIONER'S STUDY OF KANNADA AT THE PRE-UNIVERSITY COURSE (PUC) LEVEL AND/OR HIS KPSC KANNADA LANGUAGE TEST CERTIFICATE AS SUFFICIENT COMPLIANCE WITH THE LANGUAGE REQUIREMENT OF THE 2017 RECRUITMENT NOTIFICATION AND ETC.,

THIS PETITION, COMING ON FOR ORDERS, THIS DAY, ORDER WAS MADE THEREIN AS UNDER:

CORAM: HON'BLE MR. JUSTICE S.R.KRISHNA KUMAR

ORAL ORDER

In this petition, petitioner seeks for the following reliefs:-

a) Issue a Writ of Mandamus directing the Respondents to consider the representation dated: 06.02.2026 of the petitioner vide Annexure-H and consequently consider petitioner’s study of Kannada at the Pre-University Course (PUC) level and /or his KPSC Kannada Language Test certificate as sufficient compliance with the language requirement of the 2017 Recruitment Notification.

b) In the Alternative, issue a direction to the Respondents to permit the petitioner to appear for a remedial Kannada Language Test, as provided for in the notification, by issuing a specialized hall ticket and conducting the same within a stipulated time frame.

c) Issue a Writ of Mandamus directing Respondent No.1 and 2 to include the petitioner’s name in the final selection list for the post of Assistant Engineer (Mechanical)-NHK Cadre, based on his merit score of 65.671, and issue an appointment letter subject to other eligibility criteria.”

2. Briefly stated the facts giving rise to the present petition are as under:-

On 03.08.2017, the 2nd respondent – Karnataka Power Corporation Limited (KPCL) issued a Modified Recruitment Notification inviting applications from competent qualified personnel for 622 posts of AE / JE / Chemist / Chemical Supervisor. Clause No.8 of the said Notification prescribed “Kannada Language Test” as an eligibility criteria interalia stating that those who had not studied Kannada as one of the subjects in SSLC or equivalent examination (CBSE/ICSE) are required to pass Kannada language test to be conducted by the 2nd respondent – KPCL and that it was only those candidates who passed the Kannada language test, would be eligible to be considered for the selection process and that the date and venue of the Kannada language test would be published separately in the KPCL website.

2.1 The petitioner who had completed 10th standard under the CBSE Board submitted online application on 18.08.2017, wherein he marked the digital check box which asked “studied Kannada in SSLC or equivalent exams” as “Yes”. The selection process pursuant to the 1st selection examination conducted by the 2nd respondent – KPCL was cancelled on 23.08.2023 and thereafter, as per the directions which were issued by this Court, whereby the 3rd respondent – KEA was assigned the task of conducting re-examination for the aforesaid 622 posts. In pursuance of which, re-examination / 2nd examination was conducted on 18.02.2024.

2.2 The 2nd examination / re-examination also became the subject matter of litigation before the Hon’ble Division Bench of this Court in W.A.No.1298/2024, whereby the Division Bench directed re-examination / 3rd examination to be conducted by the respondents 2 and 3 and the petition in SLP No.21754/2025 was dismissed by the Apex court on 23.09.2025. It was contended by the petitioner that meanwhile, the

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2026 Supreme(Online)(Kar) 20675

THE HIGH COURT OF KARNATAKAS.R.Krishna Kumar, JNagabhushan D. Goudar – AppellantVersusKarnataka Power Corporation Limited – RespondentWP No. 4356 of 2026

Cases Referred (4)

THE HIGH COURT OF KARNATAKA
S.R.Krishna Kumar, J
Nagabhushan D. Goudar – Appellant
Versus
Karnataka Power Corporation Limited – Respondent
WP No. 4356 of 2026