The Uttarakhand High Court has dismissed a batch of petitions filed by candidates whose candidature for various posts under the Uttarakhand Public Service Commission (UKPSC) was rejected during document verification. The Court held that candidates who do not possess the exact qualification prescribed in the recruitment rules cannot claim appointment on the basis of allegedly equivalent or higher qualifications.
Justice Manoj Kumar Tiwari delivered a common judgment covering six connected petitions arising from the same recruitment process.
Background of the Case
The dispute arose from a UKPSC recruitment advertisement issued for posts including Investigator-cum-Computer, Assistant Statistical Officer, Assistant Research Officer and related positions.
Under the recruitment conditions, candidates were required to possess either an ‘O’ Level Diploma in Computers or a One-Year Diploma in Computer Science/Computer Application from a recognized institution, in addition to the prescribed academic qualifications.
The petitioners had participated in the selection process and, in some cases, even appeared in provisional merit lists. However, during document verification, UKPSC found that they did not possess the specific computer qualification mentioned in the advertisement.
Several petitioners relied on certificates such as ADSE (Shikhar Project) issued by Aptech Computer Education or Advanced Diplomas obtained from private institutions. They argued that these qualifications were either equivalent to or higher than the diploma required under the recruitment rules.
Arguments Before the Court
The petitioners contended that the qualifications possessed by them provided greater computer knowledge than the diploma specified in the advertisement. They argued that rejection of their candidature was unjustified because their courses covered advanced computer-related subjects.
On the other hand, UKPSC maintained that the recruitment rules and advertisement specifically prescribed certain qualifications. According to the Commission, there was no provision allowing it to treat any other qualification as equivalent to those expressly mentioned.
The Commission further submitted that candidates had declared possession of the required diploma in their applications, but during verification the documents produced did not match the prescribed eligibility criteria.
Court’s Observations
Justice Tiwari noted that recruitment authorities are bound by the eligibility conditions contained in the recruitment rules and advertisement.
Referring to several Supreme Court decisions, the Court emphasized that determining the suitability or equivalence of educational qualifications falls within the domain of the employer and recruitment authorities, not the courts.
The Court observed:
“The prescription of qualifications for a post is a matter of recruitment policy.”
The judgment further noted that where recruitment rules do not contain any provision recognizing equivalent qualifications, neither the recruiting body nor the Court can expand the eligibility conditions.
While dealing with the plea that some candidates possessed higher qualifications, the Court held that a higher qualification cannot automatically be treated as fulfilling the prescribed qualification unless the rules specifically permit such recognition.
Findings on the Petitioners’ Qualifications
In the case of candidates relying on the ADSE (Shikhar Project) certificate, the Court found that the document itself did not clearly establish that the course was a diploma in Computer Science or Computer Application.
Similarly, candidates holding Advanced Diplomas from private institutions could not succeed because the advertisement required a specific qualification and did not contain any clause permitting consideration of equivalent qualifications.
The Court also declined to examine allegations that some other candidates had been appointed on the basis of similar qualifications, observing that those appointments were not under challenge in the present proceedings.
Decision
Dismissing all the petitions, the High Court held that candidates who do not possess the exact qualification prescribed under the recruitment rules cannot be treated as eligible merely because they claim to hold an equivalent or higher qualification.
“The writ petitions fail and are dismissed,” the Court concluded, while making no order as to costs.
Case Details:
Case Title: Sadhana v. State of Uttarakhand and Another & Connected Matters
Case Number: Writ Petition No. 1692 of 2025 (SS) and connected petitions
Judge: Justice Manoj Kumar Tiwari
Decision Date: April 21, 2026
