1. Writ appeal against Single Judge order allowing writ petition challenging rejection of candidature for statistical officer post. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 )
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2026 Supreme(Telangana) 268
IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Aparesh Kumar Singh, C.J., G.M.Mohiuddin, J.
Telangana Public Service Commission (TGPSC) - Appellant
Versus
Y. Jagadish and others - Respondents
Writ Appeal No.982 of 2025
Decided On : 17-02-2026
Advocates Appeared:
For the Appellant : Sri. P.S. Rajasekhar, learned Standing Counsel
For the Respondent: Sri. D.V. Sitharam Murthy, learned Senior Counsel representing Sri M.Avinash Reddy, learned counsel
For the Appellant : Sri. P.S. Rajasekhar, learned Standing Counsel
For the Respondent: Sri. D.V. Sitharam Murthy, learned Senior Counsel representing Sri M.Avinash Reddy, learned counsel
The court ruled that "one year" of study denotes a full academic year (two semesters). It emphasized judicial deference to expert academic bodies and clarified that elucidating existing eligibility criteria does not constitute an impermissible change to the "rules of the game."
Headnote:(A) Recruitment - Educational Qualifications - Interpretation of "one year" as a paper - For a post requiring the study of a subject for "one year," such requirement is interpreted as one full academic year consisting of two semesters. Study of a subject for a single semester does not satisfy the requirement of "one year" (Paras 15, 25). Courts should ordinarily defer to the opinion of expert academic bodies regarding the equivalence or adequacy of qualifications unless such opinion is shown to be perverse, arbitrary, or mala fide (Paras 21, 22, 29i).
(B) Recruitment - "Rules of the Game" - A memorandum issued by the recruiting authority to clarify the meaning of an existing eligibility criterion does not amount to altering the "rules of the game" mid-process, particularly when the original notification already contained the requirement and the clarification precedes final selection (Paras 18, 19, 29ii).
(C) Statutory Interpretation - Parenthetical clauses - Phrases placed within parentheses in a recruitment notification act as restrictive conditions and not merely as directory or illustrative text, specifying a mandatory component of the required degree (Para 28).
(D) Service Law - Provisional Eligibility - Admission to an examination or verification of certificates is provisional and does not create an indefeasible right to appointment if the candidate is ultimately found to lack the prescribed qualifications (Paras 19, 29iii).
Facts of the case:
Candidates possessing degrees in Computer Science applied for posts of Statistical Officers. The notification required the study of Statistics as a paper for one year. The candidates had studied the subject for only one semester. The recruiting authority issued a clarification memo stating that "one year" refers to an academic year consisting of two semesters. Based on a report from a committee of subject experts, the candidates' applications were rejected. A single judge allowed the writ petition, holding that the clarification changed the rules of the game and that the study of the subject for one semester was sufficient. The recruiting authority preferred an appeal against this order.
Findings of Court:
The clarification memo did not introduce a new qualification but elucidated an existing one. The expert committee's finding that a single semester's study is insufficient to meet the "one year" requirement was not perverse or irrational. The parenthetical requirement for Statistics was a restrictive and mandatory condition that the candidates failed to meet.
Issues: Whether the study of a subject for one semester satisfies the requirement of "one year" as prescribed in a recruitment notification and whether the issuance of a clarification memo constitutes an impermissible change to the "rules of the game."
Ratio Decidendi: The court held that "one year" in an academic context refers to a full academic year. It reaffirmed that judicial review is limited in academic matters and should defer to expert bodies. Clarifications of existing criteria are permissible and do not alter the rules of selection. Parenthetical requirements in notifications are restrictive conditions that must be strictly fulfilled to ensure candidates possess the requisite competence for the post.
Result: Writ Appeal allowed.
Act Referred
Legal Category Hierarchy
- administrative law
- constitutional law
- practice and procedure
Table of Contents
2. Appellant contends one semester study does not satisfy one-year requirement; respondents argue memo changed rules mid-process. (Para 12 , 13 )
3. Memo clarified existing criterion, did not alter rules; expert opinion that one year means two semesters is deferred to. (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22 , 23 , 24 , 25 , 26 , 27 , 28 , 29 , 30 , 31 , 32 , 33 )
4. Court defers to expert bodies on academic qualification equivalence; clarification of existing criteria not a rule change. (Para 21 , 22 , 23 , 29 )
5. Writ appeal allowed; Single Judge order set aside; rejection memos upheld. No order as to costs. (Para 34 , 35 )
6. Can a recruiting authority clarify existing eligibility criteria after selection process begins?
Yes, a clarification explaining the meaning of an existing criterion is not a change in the rules of the game and is permissible. (Para 16 , 17 , 18 , 19 , 29 )
7. What is the standard of judicial review for expert opinions on academic qualifications?
Courts defer to expert opinions unless they are patently arbitrary, irrational, mala fide, or perverse. (Para 21 , 22 , 23 , 29 )
8. Does participation in a selection process confer a right to appointment?
No, participation is provisional; a candidate can be rejected at any stage if found not to possess prescribed qualifications. (Para 19 , 29 )
9. Should text within parentheses in an eligibility notification be ignored?
No, parenthetical clauses act as restrictive conditions and must be given full effect; ignoring them would defeat the notification's purpose. (Para 28 , 29 )
10. Is one state's public service commission bound by another state's commission's qualification interpretation?
No, each commission is a distinct authority with an independent mandate; it is not bound by another commission's interpretation. (Para 27 )
JUDGMENT :
This writ appeal, preferred under Clause 15 of the Letters Patent, assails the order dated 05.12.2024 passed by the learned Single Judge in W.P.No.16415 of 2021. By the impugned order, the learned Single Judge allowed the writ petition filed by the respondents herein (original writ petitioners) and directed the appellant- Commission to consider their candidature for the post of Mandal Planning and Statistical Officer/Assistant Statistical Officer strictly in accordance with G.O.Ms.No.3, Planning (Establishment) Department, dated 01.03.2012 and Notification No.12/2018, dated 02.06.2018.
Factual background (in brief)
2. On 02.06.2018, the appellant-Telangana Public Service Commission (TGPSC) issued Notification No.12/2018 inviting applications for 474 posts of Mandal Planning and Statistical Officer/Assistant Statistical Officer in the Directorate of Economics and Statistics Subordinate Services Department.
3. The educational qualifications prescribed for the said post are set out in paragraph 4 of the Notification, which are traceable to G.O.Ms.No.3, Planning (Establishment) Department, dated 01.03.2012 (whereby the Andhra Pradesh Economics and Statistical Subordinate Service Rules, 1991 were amended). The relevant portion reads as under:
4. The respondents, who are B.Tech (Computer Science) graduates, applied for the said posts and were permitted to appear for the written examination conducted on 03.09.2018 and were subsequently called for certificate verification between 10.01.2019 and 12.01.2019. During certificate verification, the Commission noticed that the respondents had studied ‘Probability and Statistics’ for only one semester (six months) in their B.Tech course, whereas the prescribed qualification required study of Statistics for ‘one year’ or ‘two years’ or ‘all the three years.’ In order to clarify the said requirement, the Commission issued a Memo dated 31.12.2018 containing the following notes as under:
Note- 1: Study of Statistics for one year or 2 semesters is necessary to be eligible for the said post.
2: As such Candidates who studied B.Tech (Computer Science) with minimum of one year study of Statistics are also eligible.
5. Aggrieved thereby, certain candidates filed W.P.No.3043 of 2019 and batch challenging the Memo dated 31.12.2018. By interim order dated 04.04.2019, this Court directed the respondents therein to consider the cases of the petitioners without reference to the Memo dated 31.12.2018 and strictly in terms of G.O.Ms.No.3. Pursuant to the said interim order, the Commission referred the matter to a Committee of Subject Experts comprising:
i) Prof. V.V. Hara Gopal, Professor of Statistics, BITS-Pilani, Hyderabad Campus;
ii) Prof. Madhuchhanda Bhattacharjee, Professor of Statistics, University of Hyderabad, Gachibowli, Hyderabad; and
iii) Prof. B. Sudhakar Reddy, Chairman, Board of Studies, Department of Economics, Osmania University, Hyderabad.
6. The Expert Committee submitted its report dated 12.04.2019 observing, inter alia, as follows:
“As per G.O.Ms.No.3 dated 01.03.2012, the ‘year’ means an academic year consisting of 12 months or two semesters of six months’ duration each.
In an academic year, the examination will be held at the end of the academic year with full coverage of Statistics, while in a semester (6 months), which is not a full academic year, where only the foundations of Statistics are being learnt.”
7. Based on the report of the Expert Committee, the appellant- Commission issued individual rejection memos dated 29.05.2019 to the respondents informing them that their candidature stood rejected on the ground that they did not possess the requisite qualification of having studied Statistics for one academic year.
8. Challenging the said rejection memos, the respondents filed the present writ petition vide W.P. No.16415 of 2021. During the pendency of the writ petition, certain subsequent developments took place, including withdrawal of W.A.No.402 of 2019 and batch by the State on 17.0
