The Supreme Court stated that courts should be careful when comparing qualifications and should consider recruitment conditions fairly.
The Supreme Court has approved the appeal of candidates chosen for Junior Engineer (Electrical) positions in Lakshadweep’s Department of Electricity. The court noted that it is the appointing authority’s responsibility to determine if a candidate meets the job requirements in cases of qualification disputes. The court was reviewing appeals from candidates whose selections were overturned by the Central Administrative Tribunal. The Division Bench, led by Justice Pamidighantam Sri Narasimha and Justice Manoj Misra, stated, “When the appointing authority has not raised concerns about the qualifications of the appellants and there is no significant difference in qualifications, we find no reason for the courts to interfere with the appointments made after proper evaluation. It is the appointing authority that must decide if the candidate meets the necessary qualifications in disputed cases.”
Advocate Meena K Poulose represented the appellants, while Advocate Amarjit Singh Bedi represented the respondents. The Lakshadweep Department of Electricity had advertised for Junior Engineer (Electrical) positions, classified as Group ‘C’. The appellants hold Diplomas in Electrical and Electronics Engineering, while the respondents have Diplomas in Electrical Engineering. Both groups participated in the selection process, with the appellants being selected. Dissatisfied, the respondents, who were not on the Select List, filed Original Applications with the Central Administrative Tribunal, which ruled in their favor.
The Tribunal annulled the selection of the appellants, stating that qualifications not mentioned cannot be included with those that are specified. The appellants then submitted writ petitions to the High Court, which were dismissed. The High Court ordered that the selection list be revised to include only candidates with the exact qualifications stated in the advertisement, meaning the eligible candidates from the new list would replace the appellants. The appellants were among those listed in the original selection. The Apex Court issued a notice and put a hold on the High Court’s decision while the Special Leave Petition was being reviewed. This situation brought the case to the Apex Court.
The Bench referred to the Lakshadweep Electricity Department (Group ‘C’ and ‘D’ Technical Posts) Recruitment Rules, 2002, which detail the job requirements, including the position name, pay scale, age, and necessary qualifications. Since the recruiting authority had asked if a Diploma in Electrical and Electronics Engineering is equivalent to a Diploma in Electrical Engineering and accepted that it is, the Bench found no reason to reject this equivalence for the advertisement. The Respondents did not provide any justification for denying this equivalence in their OA. It was noted that the administration had clearly stated before the CAT and the High Court that the two degrees are considered equivalent for recruitment to the position. The Bench remarked that both CAT and the High Court overlooked the recruiting authority’s efforts to compare the two qualifications before the advertisement was issued.
The court referred to the case of Union of India v Uzair Imran (2023), highlighting the need for caution when comparing qualifications. The Bench noted that there was no evidence showing that the Respondents provided convincing proof that their qualifications were significantly different from those of the appellants. The employer demonstrated efforts to show that the Diploma in Electrical and Electronics Engineering matched the qualifications listed in the job advertisement. The Bench stated that even if the High Court had some reason to review the case, it should adopt a reasonable approach, as mentioned in Uma Shankar Sharma v. Union of India, to ensure that the terms of service are interpreted fairly and not too technically, which could undermine their true purpose. Given the established law and the lack of objections from the employer regarding the appellants’ diplomas, the High Court’s technical stance was deemed inappropriate, leading to the decision to overturn the CAT and High Court rulings, thus allowing the appeals of the appointed candidates.
Cause Title: Sajid Khan v. L Rahmathullah & Ors. (Neutral Citation: 2025 INSC 251)
Appearance:
Appellants: AOR Sanand Ramakrishnan, AOR C. K. Sasi, Advocate Meena K Poulose, AOR Manu Krishnan G
Respondents: AOR Sanand Ramakrishnan, Advocates Amarjit Singh Bedi, Surekha Raman, Shreyash Kumar, Harshit Singh, Imlikaba Jamir, Yashwant Sanjenbam, Sidharth Nair, AOR M/S. K J John And Co, AOR Manu Krishnan G, AOR C. K. Sasi
