The Madhya Pradesh High Court has dismissed a batch of petitions filed by candidates whose applications for the post of Assistant Professor (Zoology) were rejected by the Madhya Pradesh Public Service Commission (MPPSC). The Court held that determining whether one academic qualification is equivalent to another falls within the domain of expert bodies and the employer, not the judiciary.
Background of the Case
The lead petition was filed by Dr. Rahul Patidar, who had applied under the OBC category for the post of Assistant Professor (Zoology) pursuant to MPPSC Advertisement No. 51/2022. After clearing the written examination, he was placed in the provisional selection list and submitted his documents for verification.
However, MPPSC later rejected his candidature, stating that he did not possess the prescribed educational qualifications. Although Dr. Patidar submitted a representation claiming that his M.Sc. (Agriculture) in Entomology is an allied subject of Zoology, MPPSC maintained that his postgraduate degree, Ph.D., and NET qualification were all in the Agriculture discipline and therefore did not satisfy the eligibility conditions prescribed for the Zoology post. Similar issues were raised in four connected writ petitions.
Petitioners' Arguments
The petitioners argued that Entomology is a recognized branch of Zoology and that rejecting their candidature merely because the degree was awarded under the Agriculture stream was arbitrary. They also relied on the MPPSC State Eligibility Test (SET)-2024 notification, which treated Entomology as an allied subject under Life Sciences.
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It was further argued that changing the reasons for rejection and denying them a personal hearing violated the principles of fairness and natural justice. The petitioners also referred to the UGC Regulations, 2018, to contend that allied and interdisciplinary subjects should receive due recognition.
Respondents' Stand
The State and MPPSC submitted that the Commission functions only as the recruiting agency and is bound by the eligibility criteria fixed by the Higher Education Department. According to the respondents, the recruitment rules specifically required a Master's degree in Zoology or one of the notified allied subjects, along with a NET qualification in Life Sciences.
They informed the Court that an expert committee examined the candidates' qualifications and concluded that M.Sc. (Agriculture) in Entomology and Agriculture Entomology NET did not satisfy the prescribed requirements. The respondents also relied on the Supreme Court's decision in Zahoor Ahmad Rathor v. Sheikh Imtiyaz Ahmad to argue that prescribing qualifications is a matter of recruitment policy.
Court's Observations
Justice Jai Kumar Pillai observed that constitutional courts exercising jurisdiction under Article 226 cannot function as academic authorities to determine the equivalence of educational qualifications.
The Court noted that the advertisement clearly prescribed the required qualifications and that the petitioners admittedly possessed degrees and NET qualifications in Agriculture Entomology rather than the specified subjects.
"The Court observed, 'The constitutional courts do not possess the requisite expertise to assess the equivalence of degrees, and therefore, cannot substitute their views for those of academic experts.'"
The Bench further held that the qualifications had been evaluated by an independent expert committee constituted by the Higher Education Department, and there was no reason for judicial interference with its academic assessment.
The Court also rejected the argument based on the SET examination, observing that qualifying NET or SET does not itself confer eligibility for a recruitment process where the employer has prescribed specific educational qualifications.
Emphasising the importance of adhering to recruitment advertisements, the Bench observed that allowing candidates with qualifications outside the notified criteria would be unfair to others who may have refrained from applying because they did not satisfy the published eligibility conditions.
Decision
Finding no legal, procedural or constitutional infirmity in the action of the respondents, the High Court held that the petitioners could not claim eligibility contrary to the express recruitment rules and advertisement. Accordingly, all the connected writ petitions were dismissed, with no order as to costs.
Case Details:
Case Title: Dr. Rahul Patidar v. State of Madhya Pradesh and Others
Case Number: Writ Petition No. 42965 of 2025 (along with connected writ petitions)
Judge: Justice Jai Kumar Pillai
Decision Date: 1 July 2026
