University Cannot Reject Candidate's Degree For Recruitment After Accepting Him For PhD Based On Same Qualification: HP High Court

The Himachal Pradesh High Court held that a university can't apply inconsistent standards by treating a candidate's Master's degree as an eligible subject for PhD admission but ignoring the same qualification during selection for the post of Assistant Professor.

Justice Sandeep Sharma remarked that: “...respondents are estopped from adopting different yardsticks while considering M.Sc. (Botany) as 'concerned' subject for Ph.D. and ignoring the same... for the post of Assistant Professor.”

The petitioner, Seema Sharma worked as Guest Faculty in the Department of Forest Products and in 2022 she applied for the posts of Assistant Professor.

She submitted that the University had previously granted her marks for M.Sc. (Botany) during Ph.D. admission and Guest Faculty engagement. However, she was excluded from the merit list as the University refused to give her any marks for that degree during the selection process of Assistant Professor.

She further contended that the University could not treat her Master's qualification differently at different stages, especially when she fulfilled the criteria as the recruitment advertisement required a Ph.D. in the concerned subject with a good academic record.

In response, the University contended that marks were allotted only for the Master's degree in the concerned subject, and Botany is not an allied subject.

Case Name:Seema Sharma v/s Dr. Y.S. Parmar University of Horticulture and Forestry and Anr.

Case No.: CWP No.3257 of 2023

Date of Decision: 24.11.2025

For the Petitioner: Mr.Sanjeev Bhushan, Senior Advocate with Mr.Sparsh Bhushan, Advocate

For the Respondents: Mr. Ramesh Sharma, Advocate, for respondent No.1.

Mr.Dilip Sharma, Senior Advocate with Mr. Manish Sharma, Advocate, for respondent No.2

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