Chhattisgarh High Court Strikes Down Rule Prescribing Only Diploma Holders as Eligible for Sub-Engineer Posts

In a significant and far-reaching judgment, the Chhattisgarh High Court has struck down a provision that limited eligibility for the post of Sub-Engineer in the Public Health Engineering (PHE) Department exclusively to candidates holding a diploma in engineering. The Court held that such a provision, which disqualified engineering degree holders from applying for the post, was arbitrary, discriminatory, and violative of constitutional principles, particularly Articles 14 and 16 of the Constitution of India. The decision is expected to have a substantial impact on recruitment policies in the state and serves as a reminder to all authorities to ensure that qualification-based restrictions in public employment are rational and justifiable.

The matter was brought before the Court by a group of petitioners who were engineering graduates and had been barred from applying for the Sub-Engineer position due to a recruitment rule that required candidates to hold only a three-year diploma in engineering. These graduates challenged the rule as being unconstitutional and contrary to the principles of equality and fairness. They argued that holding a higher qualification should not act as a disqualification and that excluding them from applying was both irrational and detrimental to the public interest.

The impugned rule was part of the Chhattisgarh Public Health Engineering (Non-Gazetted) Service (Recruitment and Conditions of Service) Rules, 2016. Specifically, Rule 8(II), Column (5), Schedule III, Entry No. 1, stated that only candidates with a diploma in engineering would be eligible for direct recruitment as Sub-Engineers. This was interpreted by the recruiting authorities to mean that candidates with a degree in engineering were not eligible to apply. The petitioners submitted that this interpretation was not only legally flawed but also contrary to previous practices and recruitment rules, such as the 2012 rules, which recognized the diploma as a minimum qualification and did not exclude graduates.

The State government and the concerned authorities defended the rule by claiming that it was consistent with earlier recruitment frameworks and that a diploma was the appropriate qualification for the Sub-Engineer post due to the nature of the job. They also stated that engineering graduates had opportunities for promotion within the department through other provisions and that the 5% reservation for degree holders in promotion channels was sufficient to accommodate them. However, the Court found this reasoning inadequate and lacking a sound legal basis.

In its judgment, the High Court emphasized that classification in public employment must be based on intelligible differentia and must have a rational nexus with the objective sought to be achieved. The Court held that excluding engineering degree holders from being considered for a technical post such as Sub-Engineer, while allowing diploma holders, amounted to irrational classification. It also observed that similar posts in other departments such as the Public Works Department and the Chhattisgarh State Power Distribution Company Limited allowed both diploma and degree holders to apply, thereby further exposing the arbitrary nature of the PHE Department’s rule.

The Court underscored that the role of a Sub-Engineer is fundamentally technical in nature and requires engineering knowledge. There is no rational justification for preferring diploma holders over degree holders when the latter have undergone a more advanced and comprehensive education in the same field. In fact, the Court observed that such exclusion of degree holders not only undermines meritocracy but also dilutes the quality of public services by limiting the talent pool.

Furthermore, the Court dismissed the argument that diploma holders are more suited for the job due to practical training. It clarified that eligibility criteria must be guided by the nature of duties and the competencies required, and not by arbitrary assumptions. Engineering graduates, having covered the core curriculum of diplomas and additional advanced subjects, are not only eligible but often better equipped to handle the responsibilities of a Sub-Engineer.

The Court also drew attention to the principle that possessing a higher qualification does not automatically imply over-qualification unless it is explicitly proven that such qualifications are unsuitable or would interfere with the performance of duties. In the present case, there was no such evidence. Instead, the exclusion appeared to be rooted in administrative rigidity rather than a well-reasoned policy decision.

By striking down the diploma-only eligibility rule, the High Court also acknowledged the interim order it had previously issued, which had allowed degree holders to appear in the Sub-Engineer examination conditionally. Following the final judgment, the Court directed that their exam results be considered and the recruitment process be concluded by including all eligible candidates, irrespective of whether they hold a diploma or a degree, subject to satisfying other applicable criteria such as age limits and reservation norms.

The Court’s decision also sends a strong message to public authorities to ensure that rules regarding recruitment and eligibility must reflect current educational and professional standards and should not operate to unjustly exclude deserving candidates. It stressed that public employment is a matter of public trust, and recruitment rules must serve the interest of efficiency, fairness, and transparency. Arbitrary disqualification on the basis of higher qualification defeats these objectives and discourages merit.

This ruling is likely to have broader implications beyond the PHE Department. It sets a precedent that may prompt a review of recruitment rules in other departments and state institutions that have similar restrictions. It may also encourage affected candidates in other jurisdictions to seek legal recourse against exclusionary and irrational qualification norms.

In essence, the Chhattisgarh High Court has upheld the constitutional mandate of equality in public employment and has rightly reminded state authorities that recruitment rules must be framed with a view to promoting competence and fairness, rather than erecting artificial and unjustifiable barriers. The judgment is a significant development in service jurisprudence and a welcome reaffirmation of the legal principle that higher qualifications should be seen as an asset, not a liability, in public service recruitment.