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2026 Supreme(Online)(Tel) 12425

IN THE HIGH COURT FOR THE STATE OF TELANGANA AT HYDERABAD
Aparesh Kumar Singh, CJ, G.M.Mohiuddin, J
Telangana Public Service Commission – Appellant
Versus
Yenagandula Mahender – Respondent
W.A.Nos.337, 338, 341 and 342 of 2026



Advocates:
For the Appellants/Petitioners: P.S.Rajasekhar
For the Respondents: M.V.Rama Rao, M.Surender Rao, Srinivasa Rao Madiraju, S.Suman

Degrees obtained through distance education study centres operating outside the territorial jurisdiction of the parent university are invalid for public employment, and the principle of equality under Article 14 of the Constitution cannot be invoked to perpetuate or claim legitimacy for past illegal appointments.

Headnote:(A) Universities Act, 1991 - Territorial jurisdiction - Distance education - Recruitment notification - Candidates obtained degrees through distance education from study centres located outside the territorial jurisdiction of the parent University - Legality of such degrees for public employment.

(B) Constitution of India - Article 14 and 16 - Doctrine of negative equality - Past instances of appointments of similarly situated candidates cannot be a ground to perpetuate illegality - Illegality committed in favour of individuals does not grant a right to others to demand similar treatment.

Facts of the case:
The appellant issued recruitment notifications for various posts. The private respondents participated and submitted degrees obtained via distance mode from a University situated in another state, through study centres located in the State of Telangana. The appellant rejected their candidature based on University Grants Commission stipulations and recruitment conditions restricting study centres beyond the University's territorial jurisdiction. The learned Single Judge set aside the rejection based on parity with earlier appointments.

Findings of Court:
The degrees obtained through study centres outside the territorial jurisdiction of the parent University are invalid for public employment. The reliance on transition provisions of the Reorganisation Act is misconceived. Past irregular appointments do not justify perpetuating the same illegality.

Issues: Whether degrees acquired through distance education via study centres outside the territorial jurisdiction of the parent University are valid for public employment and whether the doctrine of equality can be invoked to claim parity in an illegality.

Ratio Decidendi: Degrees obtained through extraneous study centres in violation of mandatory regulatory and statutory frameworks lack validity. Article 14 cannot be invoked to claim negative equality or to repeat past illegalities.

Result: Appeals allowed; orders of the Single Judge set aside and writ petitions dismissed.

Table of Content
1. summary of facts, procedural history, and initial claims regarding employment eligibility based on distance education. (Para 1 , 2 , 3 , 4 , 5 , 6 , 7 , 8 , 9 , 10 , 11)
2. parties' contentions regarding territorial jurisdiction of universities and the applicability of equality protections. (Para 12 , 13 , 14)
3. court's legal analysis on degree validity, territorial limits, and the rejection of negative equality. (Para 15 , 16 , 17 , 18 , 19 , 20 , 21 , 22)
4. final ruling and formal disposal of the appeals based on established illegality. (Para 23 , 24)

COMMON JUDGMENT

(Per Hon’ble Sri Justice G.M.Mohiuddin)

Since the issues that arise in the above writ appeals are integrally one and the same, the writ appeals are being disposed of by this Common Judgment.

2. W.A.No.337 of 2026 is directed against W.P.No.37361 of 2025; W.A.No.338 of 2026 is directed against W.P.No.30708 of 2025; W.A.No.341 of 2026 is directed against W.P.No.30836 of 2025 and W.A.No.342 of 2026 is directed against W.P.No.30699 of 2025.

3. All the aforesaid writ appeals are against orders dated 16.12.2025 passed in W.P.Nos.37361, 30708, 30836, and 30699 of 2025 by the learned Single Judge.

4. Heard Sri P.S.Rajasekhar, learned Standing Counsel for Telangana Public Service Commission for appellant; Sri. M.V.Rama Rao, learned counsel appearing for respondent No.1 in W.A.No.337 of 2026; Sri M.Surender Rao, learned Senior Counsel representing Sri Srinivasa Rao Madiraju, learned counsel for respondent Nos.1 in W.A.No.338, 341 and 342 of 2026; Sri. S.Suman, learned Government Pleader for Services-III appears for respondent No.2 in W.A.No.338 of 2026 and perused the record.

Factual matrix

5. The appellant – Telangana State Public Service Commission (hereinafter referred to as, “TGPSC”) issued recruitment notifications bearing Notification Nos.29 of 2022 and 11 of 2022 for filling up various Group–III posts, including the post of Extension Officer (Supervisor) Grade–I. Pursuant thereto, the respondents–writ petitioners (hereinafter referred to as “the private respondents”), who are residents of the State of Telangana, applied for the said posts and participated in the selection process, on the basis of the requisite educational qualifications possessed by them, namely Bachelor of Commerce (B.Com) and/or Master of Arts (M.A.) in Sociology/Social Work, which were obtained through the distance education mode from Acharya Nagarjuna University (ANU), a State University situated in Guntur, Andhra Pradesh.

6. A statement showing the writ appeals and the writ petitions arising and the corresponding notification along with the date and the post notified thereunder and the qualifications of the writ petitioners, is tabulated hereunder for the sake of convenience:

WA’s WP’s Notification Date Post Qualification From
337/2026 37361/2025 29/2022 30.12.2022 Gr.III B.Com ANU
338/2026 30708/2025 11/2022 27.08.2022 EO Group-I MA (Sociology) ANU
341/2026 30836/2025 11/2022 27.08.2022 EO Group-I MA (Sociology) ANU
342/2026 30699/2025 11/2022 27.08.2022 EO Group-I MA (Social Work) ANU

7. However, the said courses were pursued by them through study centres of the said University located within the State of Telangana, including through arrangements which were in the nature of study centres, operating beyond the territorial jurisdiction of the parent University.

8. During the process of certificate verification, the TGPSC scrutinised the educational credentials of the candidates with reference to the conditions stipulated in the recruitment notifications and upon such verification, the candidature of the private respondents came to be rejected on the ground that the degrees obtained by them through distance mode from study centres situated outside the territorial jurisdiction of ANU were not valid, in view of the binding norms prescribed by the University Grants Commission (UGC), more particularly Public Notice No.F.27-1/2012 (CPP-II) dated 27.06.2013. The said stip

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