On Thursday, the Supreme Court, while addressing the boundaries of eligibility criteria in public recruitment, examined whether a candidate who studied Statistics as a principal subject, but did not hold a degree titled expressly in that discipline, could be denied appointment solely on nomenclature. In resolving the dispute, the Court held that academic terminology cannot be preferred over substance, especially when the course structure demonstrates core subjects in Statistics.
Brief Facts:
The case stemmed from a recruitment advertisement requiring a postgraduate degree in Statistics for the post of Monitoring and Evaluation Consultant. The appellant, holding an M.Com degree with Business Statistics and Indian Economic Statistics as principal subjects, was appointed after verification of his credentials but was later terminated when an internal committee found him ineligible. Despite subsequent certification from his institution and a departmental opinion confirming that he met the requirement and recommending continuation, fresh termination orders were issued on the ground that he did not possess a formal Statistics degree. The High Court upheld the termination at both stages, leading to the present appeal before the Supreme Court.
Contentions of the Appellant:
The Appellant submitted that the authorities disregarded documents certifying his eligibility, including confirmation that Statistics formed a principal part of his postgraduate curriculum. He argued that no Government university in the State offered a degree titled “Statistics,” making a literal interpretation unreasonable, and claimed that similarly placed employees continued in service while he alone was singled out. He further asserted that the inquiry lacked procedural fairness and that relevant material proving eligibility was ignored, warranting reinstatement.
Contentions of the Respondent:
The Respondents maintained that the recruitment expressly required a postgraduate degree in Statistics, which the appellant did not possess, and that related subjects within an M.Com programme could not satisfy the prescribed qualification. They relied on the findings of the inquiry and repeated reconsideration, arguing that prescribed criteria cannot be expanded or treated as equivalent, and that negative equality cannot apply. The State submitted that the appellant’s contractual engagement conferred no right to continuation, and the termination was lawful.
Observation of the Court:
The Bench held that “insisting solely on the title of the degree, without considering the actual curriculum, amounts to elevating form over substance. The law does not compel such an interpretation. In our view, considering the facts of the present case, the expression “Postgraduate degree in Statistics” must be understood contextually and purposively.” The Court acknowledged precedent limiting judicial intervention in academic matters but observed that the appellant was not seeking equivalence with a different qualification, rather asserting fulfilment of the prescribed requirement when read reasonably.
The Court emphasised that the appellant was not seeking equivalence with a different qualification, but asserting fulfilment of the prescribed criteria when interpreted reasonably and purposively. It was also recorded that the termination was founded upon a committee report later proven factually incorrect, and which was prepared without giving the appellant an opportunity to be heard, breaching the principles of natural justice.
The Court observed that “the continued reliance on the said report in the subsequent termination orders dated 02.11.2018 and 14.05.2020, without examining relevant and material documents placed on record, renders the said orders arbitrary, uninformed and unsustainable in law.” The Bench also relied upon a later departmental communication affirming that the appellant’s studies in Quantitative Methods, Business Statistics and Economic Statistics satisfied the advertised educational requirement.
Finding no rational basis for treating the appellant differently from similarly qualified candidates, the Court held that such a distinction offended Article 14 of the Constitution and violated the State’s obligation of fairness even in contractual employment.
The decision of the Court:
In light of the foregoing discussion, the Court held that the appellant possessed the requisite qualification when reasonably interpreted in the context of the recruitment conditions and that the decision terminating his services was arbitrary. The appeal was allowed, the impugned judgment set aside, and the appellant was directed to be reinstated to the post of Monitoring and Evaluation Consultant with all consequential benefits, subject to the absence of any other disqualification.
Case Title: Laxmikant Sharma v. State of Madhya Pradesh & Ors.
Case No.: SLP (C) No. 18907 of 2025
Coram: Hon’ble Mr. Justice Sanjay Karol and Hon’ble Mr. Justice Vipul M. Pancholi
Advocate for the Appellant: AOR Mrigank Prabhakar, Advs. Siddharth R. Gupta, U.N. Pandey, Aman Agarwal, Uddaish Palya, Surbhi Saxena, Siddharth Sahu, and Astha Singh.
Advocate for the Respondent: AOR Pashupathi Nath Razdan, Advs. Sarthak Raizada, Maitreyee Jagat Joshi, Astik Gupta, and Akanksha Tomar.
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