Education obtained through distance learning must be equitably valued in promotion policies unless explicitly stated otherwise in official documents.

WA No.2732 of 2025 ….......................................................... Dated this the 9^th day of January, 2026 JUDGMENT P.V. Balakrishnan , J.

This intra-court appeal is filed by the petitioner in W.P.(C)

No.19108 of 2024, challenging the judgment dated 15.10.2025 dismissing her writ petition.

2. The appellant/writ petitioner entered the service of the first respondent on 01.06.2016, as Assistant Manager. Later, she was promoted as manager in 2019, as per Ext.P9 circular. At the time of her appointment, the appellant had an MSc Degree in Physics, awarded by Mahatma Gandhi University, in 2006. Later, she also obtained an MBA degree with elective group Marketing in 2008, and an MBA Degree (HRM) in 2013, from Alagappa University, through distance education. During 2023, the appellant's name was included in the zone of consideration for promotion to the post of Deputy General Manager. But the appellant was not invited by the Departmental Promotion Committee (DPC) for interview, and out of the 14 candidates who attended the interview, 12 of them were promoted to the post of Deputy General Manager w.e.f. 01.07.2023, as per Ext P14 order. Subsequently, on the basis of a representation submitted by the appellant, she was also directed to appear for a DPC interview, on 06.12.2023. But even thereafter, the appellant was not promoted, and instead the 7^th respondent was promoted by Ext.P20 order, dated 27.12.2023. The appellant, on making inquiries under the Right of Information Act, obtained Ext.P23 information from the 1^st respondent regarding the reasons for denying promotion to her. From it, she understood that her MBA degree obtained through correspondence course was considered as a "lower qualification" and that she was awarded a lesser mark in the interview. She also understood that while the other candidates, who have undergone a full-time MBA course, were granted the minimum 20 marks prescribed, the appellant was granted only 15 marks. According to the appellant, even though as per Ext.P11 Rules/promotion policy, the minimum educational qualification prescribed for promotion to the post of Deputy General Manager is a full-time MBA in the relevant field from a recognized university, the said qualification was relaxed/modified by Ext.P12, making an MBA through distance education equivalent to a full-time MBA course. Even though an appeal was preferred by the appellant before the 1^st respondent, the same got rejected as per Ext. P22 letter, dated 30.03.2024. It is in such circumstances, the appellant filed the afore writ petition, seeking the following reliefs:

''I. call for the records leading to Exts.P14, P20 and P22 and quash them to the extent petitioner is denied promotion to the category of Deputy General Manager and respondents 3 to 7 are promoted as such, by the issuance of a writ of certiorari or any other appropriate writ, order or direction.

II. declare that petitioner is entitled to be given five more marks for educational qualification and be promoted to the category of Deputy General Manager with retrospective effect from 01.07.2023 with all consequential service and monetary benefits, including back wages.

III. issue a writ of mandamus or any other appropriate writ, order or direction commanding respondents 1 and 2 to award the full marks of 20 to the petitioner for her educational qualification (Ext.P2 MBA Degree) in connection with promotion to the category of Deputy General Manager for the year 2023 and accordingly revise the DPC merit list and to grant her promotion as Deputy General Manager with retrospective effect from 01.07.2023, with all consequential service and monet