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2026 Supreme(Mad) 518

IN THE HIGH COURT OF JUDICATURE AT MADRAS
M.DHANDAPANI, J.
S. Arun – Appellant
Versus
The State of Tamil Nadu – Respondent
W.P. Nos. 1863, 1868 of 2026, W.M.P. Nos. 1906, 1957, 1960, 1961 of 2026
Decided On : 28-01-2026

Advocates Appeared:
For the Appellants : G. Sankaran, S. Nedunchezhiyan
For the Respondents: J. Ravindran, K. Tippusulthan, Mohd. Sathik

The equivalence of educational qualifications for employment must be assessed based on syllabus similarity rather than course nomenclature changes.

Headnote:(A) Constitution of India - Article 226 - Writ of certiorarified mandamus - Challenge to non-inclusion of names in provisional selection list for Health Inspector Grade-II due to diploma qualification disputes - Petitioners argued legitimate grounds for inclusion based on equivalence certificates per G.O. Ms. No.45 and G.O. Ms. No.338 regarding syllabi equivalence. (Paras 1, 5, 37)

(B) Legal principles - The concept of 'equivalence' should consider the syllabus rather than the nomenclature of the course for employment eligibility purposes. (Paras 17, 37)

Facts of the case:
Petitioners submitted applications for Health Inspector Grade-II based on marks obtained in a written examination, but were excluded based on qualification nomenclature differences. (Paras 2-6)

Findings of Court:
The court found the petitioners' qualifications were equivalent to those required for selection as per applicable government orders, thus allowing their inclusion in the selection list. (Paras 38)

Issues: Whether the change in course nomenclature affects the equivalence, and if non-inclusion of petitioners was proper. (Paras 4, 12, 36)

Ratio Decidendi: The court emphasized that syllabus consistency is paramount when determining educational equivalency; hence, nomenclature changes alone should not deny eligibility. (Paras 17, 37)

Result: Writ petitions allowed; names of the petitioners to be included in the provisional list.

Table of Content
1. challenge to non-inclusion in selection list. (Para 1 , 2)
2. legal arguments regarding qualification equivalence. (Para 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10)
3. respondents defend non-inclusion based on qualifications. (Para 11 , 12 , 13 , 14 , 15)
4. court's analysis of equivalence based on syllabus and qualifications. (Para 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 , 34 , 35 , 36 , 37)
5. court orders inclusion of petitioners in selection list. (Para 38)

ORDER :

1. Challenge through these writ petitions is made to the non-inclusion of the names of the petitioners in the provisional list for selection to the post of Health Inspector Grade-II on the ground that the diploma qualification of the petitioners is not equivalent to the qualification, which was advertised by the 3rd respondent.

2. It is the case of the petitioners that pursuant to the advertisement issued by the 3rd respondent for selection to the post of Health Inspector Grade-II in the Tamil Nadu Public Health Subordinate Service vide notification dated 27.10.2025 the petitioners submitted their candidature and they were shortlisted for certificate verification based on the marks secured by them in the written examination. However, to their shock and surprise, the names of the petitioners were not included in the provisional selection list published by the 3rd respondent on 13.01.2026, whereas the candidates, who secured lesser marks than the petitioners have been than the petitioners have been included in the provisional list. Aggrieved by the non-inclusion of their names in the provisional selection list, the present petitions have been filed by the petitioners.

3. Learned senior counsel appearing for the petitioners submitted that the impugned provisional selection issued by the 3rd respondent dated 13.1.2026 is ex facie arbitrary, illegal and against law and the same is liable to be quashed.

4. It is the further submission of the learned senior counsel that one of the qualification criteria fixed in the advertisement is Health Inspector Course Certificate offered by the Government of Tamil Nadu. The petitioners have qualified themselves with a one year PG Diploma in Sanitary Inspector course offered by the Madurai Kamaraj University, which is an eligible qualification for the said post as notified in G.O. Ms. No.45 dated 19.4.2022, which declares the equivalence of P.G. Diploma in Environmental Sanitation Science (for short PG- ESS’) offered by Madurai Kamaraj University as equivalent to Sanity Inspector Certificate Course conducted by the Government of Tamil Nadu.

5. It is the further submission of the learned senior counsel that the aforesaid course offered by the University, which was previously offered for one year, was renamed as PG Diploma in Sanitary Inspectors Course (for short ‘PG-SI’) for a period of one year from the academic year 2018-2019. It is further submitted by the learned senior counsel that there is no change in syllabus, course content, curriculum, etc., and the change in nomenclature was made and approved only to avoid confusion with regard to eligibility of the said PG diploma course.

6. It is the submission of the learned senior counsel that when the PG-ESS has been declared as equivalent to the Sanitary Inspector course offered by the Government of Tamil Nadu, as notified in G.O. Ms. No.45 dated 19.4.2022, the change in nomenclature, without there being any change in the syllabus will not take away the eligibility of the candidates, who have completed PG-SI course from the year 2018-2019. It is therefore the submission of the learned senior counsel that the candidates, who have secured the very same qualification by studying the very same syllabus, cannot be deprived of selection merely based on the change of name of the course, when the syllabus remains intact with no change in the curriculum or its contents.

7. In this backdrop, learned senior counsel, pointing out to G.O. Ms.No.443 date

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