The Supreme Court of India has ruled that candidates possessing higher degrees cannot be rejected solely on that basis when a lower qualification is prescribed for a particular post. The judgment was delivered in the case Chandra Shekhar Singh & Others v. State of Jharkhand & Others by a bench comprising Justices Vikram Nath and Sandeep Mehta.
Background of the Case
The appellants, who hold postgraduate degrees in Microbiology and Food Science and Technology, applied for the post of Food Safety Officer (FSO) in Jharkhand under Advertisement No. 01/2016 issued by the Jharkhand Public Service Commission (JPSC). Despite being successful in the written examination, they were disqualified during the recruitment process on the grounds that their qualifications did not align with the prescribed eligibility criteria.
The advertisement required candidates to hold a degree in specific subjects such as Food Technology, Dairy Technology, Biotechnology, Oil Technology, Agricultural Science, Veterinary Science, Biochemistry, or Microbiology. It also permitted candidates with a Master’s degree in Chemistry. However, the authorities interpreted this requirement restrictively, disqualifying candidates who held Master’s degrees in the relevant subjects but not a Bachelor's degree.
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The appellants challenged their disqualification in the Jharkhand High Court, which ruled against them. The Single Judge and Division Bench upheld the recruitment advertisement’s conditions, stating that a Master’s degree in the relevant subjects did not qualify when the requirement was a Bachelor’s degree.
Aggrieved by this decision, the appellants approached the Supreme Court.
The Supreme Court analyzed the statutory provisions, including the University Grants Commission (UGC) Act, 1956, and the Food Safety and Standards Act (FSS Act), 2006. The Court noted that the term 'degree' under Section 22(3) of the UGC Act includes a Bachelor's, Master's, and Doctorate degree unless explicitly excluded.
"The term 'degree' as defined under Section 22(3) of the UGC Act includes Bachelor’s, Master’s, and Doctorate degrees. Unless a specific exclusion is provided, all three must be considered valid qualifications," the Court observed.
Furthermore, the Court found the exclusion of candidates holding Master’s degrees in subjects other than Chemistry to be arbitrary and irrational.
"There is no logic or rationale behind excluding candidates with Master’s or Doctorate degrees in these subjects from the selection process, as such an interpretation would be unjust, arbitrary, and unconstitutional."
The Court also ruled that the State Government of Jharkhand had no authority to impose additional restrictions or interpretations on qualifications for the FSO post beyond what was prescribed by the Central Government. The power to prescribe qualifications for the post of FSO lies exclusively with the Central Government under Sections 37, 91, and 94 of the FSS Act.
"The FSS Act does not permit the State Government to transgress into the domain of prescribing qualifications for the FSO post, which lies within the exclusive jurisdiction of the Central Government," the judgment stated.
In light of these findings, the Supreme Court set aside the impugned judgment of the Jharkhand High Court and ruled that the appellants were qualified for the post of FSO under the recruitment advertisement.
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The Court issued the following directives:
- The appellants should be reconsidered for appointment from the stage at which they were disqualified (i.e., the interview stage).
- If vacancies no longer exist under the 2016 recruitment process, supernumerary posts must be created to accommodate the appellants.
- The appellants, if appointed, will not be entitled to back wages but will receive all service benefits on a notional basis.
- The seniority of the appellants will be fixed below the last candidate selected in the original recruitment process to avoid disturbing the seniority of already appointed candidates.
Case Title: CHANDRA SHEKHAR SINGH AND OTHERS VERSUS THE STATE OF JHARKHAND AND OTHERS
Appearance:
For Appellant(s) : Mr. Anup Kumar, AOR Mr. Vishnu Prabhakar Pathak, Adv. Ms. Shruti Singh, Adv. Ms. Pragya Chaudhary, Adv. Mr. Awanish Gupta, Adv. Mrs. Neha Jaiswal, Adv. Mr. Shivam Kumar, Adv.
For Respondent(s) :Mr. Jayant Mohan, AOR Ms. Meenakshi Chatterjee, Adv. Ms. Adya Shree Dutta, Adv. Mr. Himanshu Shekhar, AOR Mr. Parth Shekhar, Adv. Mr. Shubham Singh, Adv. Mrs. Revathy Raghavan, AOR Ms. Kavya Roy Choudhury, Adv. Mr. Rohit Gupta, Adv.
