The Supreme Court of India recently ruled that possessing a higher qualification than the required basic eligibility for a post does not automatically grant a candidate preference in recruitment. The judgment reaffirms that selection must be based on prescribed qualifications and job-specific requirements rather than a blanket rule favoring overqualified candidates.

While acknowledging that overqualification is not a disqualification in itself, the Court made it clear that there is no universal rule mandating that higher-qualified candidates should always be preferred over those with the required basic qualifications. The Court emphasized that recruitment decisions should be determined by various factors, including:

• The specific selection process rules
• The job's nature and duties
• The employer’s need for suitable personnel

"It has to be remembered that, at times, the employer's need to have the right people at the right place, and not always the higher qualified, has to be conceded," the Supreme Court observed.

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Case Background: Kerala High Court Judgment Upheld

A bench comprising Justice Dipankar Datta and Justice Manmohan made these remarks while upholding a Kerala High Court judgment regarding the appointment of a "Boat Lascar" under the Kerala State Water Transport Department. The prescribed qualification for the position was a Lascar's License, but the appellant held a higher qualification, the Syrang's License.

The Kerala Administrative Tribunal had directed the Public Service Commission to exclude ineligible candidates, leading to the cancellation of the appellant’s appointment on the grounds that he exceeded the qualification criteria. The Supreme Court upheld this decision, emphasizing that eligibility must be determined strictly by the recruitment rules and job advertisement.

The Court highlighted the potential unfairness in allowing candidates with superior qualifications to compete for lower-level positions.

"If persons holding Syrang's licence - who are obviously better equipped than persons holding Lascar's licence - are allowed to apply and participate in the process for appointment on the post of Lascar, the probability of the persons holding Lascar's licence being outperformed by the persons holding Syrang's licence would be quite high."

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This could create an imbalance, depriving eligible but less-qualified candidates of fair competition. The judgment noted that such a scenario could lead to:

• All Lascar vacancies being occupied by Syrang-licensed candidates.
• A lack of opportunities for candidates with the required Lascar’s License.
• A potential shortage of candidates in higher posts due to misallocation of resources.

The Court extended its reasoning to broader public employment policies. It acknowledged previous decisions holding that overqualification should not be seen as a disqualification but stressed that each case must be evaluated based on its unique circumstances.

"We know of decisions holding that over-qualification cannot be a disqualification since such an approach amounts to discouraging the acquisition of qualifications on the one hand and on the other, such an approach could be seen as arbitrary, discriminatory, and not in the national interest. However, this principle cannot be put in a straitjacket imposing rigid or inflexible rules or norms."

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The judgment pointed out the consequences of allowing overqualified individuals to occupy positions meant for those with lesser qualifications. It raised critical concerns:

• Would lesser-qualified individuals remain unemployed if all vacancies were filled by highly educated candidates?
• What happens when overqualified individuals leave such jobs for better opportunities, forcing the government to restart the hiring process?
• Should the state ensure that jobs meant for specific educational qualifications remain available to those who meet the minimum requirement?

Related: Supreme Court: Higher Qualification Cannot Be a Ground for Disqualification in Recruitment

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