Master's Candidates Lacking Prescribed Bachelor's Degree Not Eligible For Recruitment As Govt School Teachers: Delhi High Court

The Delhi High Court has held that possession of a Master's degree does not automatically make a candidate eligible for a post requiring a Bachelor's degree in the same subject. [2026 LiveLaw (Del) 660]A Division Bench of Justices C. Hari Shankar and Vinod Kumar thus set aside a CAT order directing the appointment of certain candidates as Domestic Science Teachers (TGTs) in Delhi government schools.It held that candidates possessing a simple BA (Pass) degree along with a Master's degree in Home Science could not be treated as fulfilling the eligibility requirement of a Bachelor's degree in Domestic Science/Home Science prescribed under the recruitment rules.“The employer has a right to specify the educational qualification required to be possessed by aspirants for the jobs advertised by him and courts should ordinarily not interfere in the same,” the Court observed.The case arose from an advertisement issued by the Delhi Subordinate Services Selection Board (DSSSB) in December 2017 inviting applications for the post of Domestic Science Teacher (TGT). The recruitment rules prescribed a Bachelor's degree in Domestic Science/Home Science from a recognised university and a Bachelor of Education with Home Science as a teaching subject.The respondents, who possessed BA (Pass) degrees and Master's degrees in Home Science, were initially selected and issued appointment letters. However, the offers were subsequently withdrawn in March 2020 on the ground that they did not possess the prescribed educational qualifications.Aggrieved, the candidates approached CAT which ruled in their favour. In Delhi government's challenge before the High Court, the candidates argued that a Master's degree in Home Science was a higher qualification than the prescribed Bachelor's degree and therefore necessarily subsumed the lower qualification. They also contended that Home Science had been taught as a subject throughout their BA course, which ought to suffice for eligibility.Rejecting the contention, the Court held that a BA (Pass) degree, even if Home Science was studied in all three years, could not be equated with a dedicated Bachelor's degree in Home Science.“We are sanguine that a Bachelor's degree in Domestic Science/Home Science is, in a sense, equivalent to an Honours Degree in that particular discipline,” the Bench observed, adding that the depth and intensity with which the subject is taught in a specialised degree programme is qualitatively different from its treatment in a BA (Pass) course.The Court further held that the recruitment rules contained no provision permitting higher qualifications to substitute the prescribed qualification. Relying on the Supreme Court decision in Zahoor Ahmed Rather v. Sheikh Imtiyaz Ahmad, the Bench observed that a higher qualification can be treated as sufficient only where the governing rules expressly provide that it presupposes acquisition of the lower qualification.The Bench distinguished earlier decisions that had recognised higher qualifications in particular factual contexts and emphasised that the issue must be decided in light of the recruitment rules governing the post in question.The Court also noted that allowing candidates with broader educational backgrounds to compete for posts requiring specialised degrees would be unfair to those who consciously chose to pursue an exclusive academic path in the subject from the undergraduate stage.“If we allow a higher degree to subsume a lower degree, the candidates who had exclusively devoted their energies in a particular subject immediately after school level... would have to compete with candidates having a graduation degree with many subjects,” the Court observed.The Bench further observed that an employer may legitimately adopt a “catch them young” policy by insisting on specialised qualifications and that courts should ordinarily respect such recruitment choices.Accordingly, the Court set aside CAT order and held that the respondents were ineligible for recruitment.Appearance: Mrs. Avnish Ahlawat, SC GNCTD (Services) with Mr. Nitesh Kumar Singh, Ms. Aliza Alam, Mr. Mohnish Sehrawat, Advs. for Petitioners; Mrs. Kajal Chandra, Ms. Hatneimawi, Mr. Suyash Swarup, Mr. Ananyay Bhardwaj, Advs. for RespondentsCase title: GNCTD v. Manu & Ors.Citation: 2026 LiveLaw (Del) 660Case no.: W.P.(C) 2818/2024Click here to read order

Master's Candidates Lacking Prescribed Bachelor's Degree Not Eligible For Recruitment As Govt School Teachers: Delhi High Court

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