Candidate Can't Be Disqualified Merely For Not Having Degree Title If Core Subject Was Studied : Supreme Court

The Supreme Court held that when a candidate has studied the requisite principal subject as part of their curriculum, their candidature cannot be rejected solely on the ground that their degree is in a different specialisation. A bench of Justices Sanjay Karol and Vipul M. Pancholi reinstated the appointment of an M. Com (Commerce) graduate as a Monitoring and Evaluation Consultant, a post requiring a postgraduate degree in Statistics, whose services were terminated solely because he did not possess a formal PG degree in Statistics, despite having studied Business Statistics and Indian Economic Statistics as principal subjects during his M.Com. Holding that the formal degree is not necessary, when the candidate had studied the requisite subjects of statistics, the Court observed, “we are of the opinion 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 case centered on an advertisement from November 2012 for the post of Monitoring and Evaluation Consultant, which mandated a "Postgraduate degree in Statistics." The Appellant, an M.Com graduate who had studied Business Statistics and Indian Economic Statistics as principal subjects, was appointed in 2013 on a contractual basis. A year later, an 8-member inquiry committee terminated his services, ruling that an M.Com degree did not meet the criterion. This began a cycle of litigation where the Madhya Pradesh High Court repeatedly set aside the termination and remanded the case back, only for the state to issue fresh termination orders citing the same grounds, prompting the Appellant to move to the Supreme Court. Setting aside the impugned order, the judgment authored by Justice Karol noted that since no government university in Madhya Pradesh offered a postgraduate degree titled "M.Com (Statistics), a literal interpretation of the advertisement, therefore, would create an "impossible standard." “Interpreting the eligibility condition in a manner that requires a degree which does not exist in any Government university is arbitrary and unrealistic.”, the court said, emphasizing that the phrase "degree in Statistics," must be read contextually to include postgraduate degrees where Statistics is a principal subject. The Court deemed fit to interfere noting that “where a contractual employee is terminated on the sole ground of ineligibility, the Court is entitled to examine whether that ground is factually correct and whether relevant material was properly considered.” Since the phrase “degree in statistics” was not purposely interpreted, the Court deemed it fit case to restore the Appellant's position, upon noting that he had studied the required subjects in Statistics to be qualified for appointment on the said post. Accordingly, the appeal was allowed. Cause Title: LAXMIKANT SHARMA VERSUS STATE OF MADHYA PRADESH & ORS.Citation : 2025 LiveLaw (SC) 1174Click here to download orderAppearance: For Petitioner(s) : Mr. Siddharth R. Gupta, Adv. Mr. Mrigank Prabhakar, AOR Mr. Un Pandey, Adv. Mr. Aman Agarwal, Adv. Mr. Uddaish Palya, Adv. Ms. Surbhi Saxena, Adv. Mr. Siddharth Sahu, Adv. Ms. Astha Singh, Adv. For Respondent(s) : Mr. Pashupathi Nath Razdan, AOR Mr. Sarthak Raizada, Adv. Ms. Maitreyee Jagat Joshi, Adv. Mr. Astik Gupta, Adv. Ms. Akanksha Tomar, Adv. Mr. Rahul, Adv.

Candidate Can't Be Disqualified Merely For Not Having Degree Title If Core Subject Was Studied : Supreme Court

Yash Mittal

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