The Supreme Court resolved a matter concerning the qualification criteria for a public appointment, holding that a candidate cannot be disqualified on the sole ground that their degree does not carry the exact title specified in the advertisement, provided they studied the required core subjects. The case concerned a recruitment advertisement for the post of “Monitoring and Evaluation Consultant” which mandated a “Post‑graduate degree in Statistics.” The appellant held an M.Com degree, with Business Statistics and Indian Economic Statistics as his principal subjects under the course curriculum. He was initially appointed on a contractual basis.
Subsequently, an 8‑member inquiry committee terminated his services, reasoning that an M.Com degree did not qualify as a postgraduate degree in Statistics because the title did not explicitly mention “Statistics.” The appellant challenged this termination before the Madhya Pradesh High Court, which set aside the termination and remanded the matter. Nevertheless, the state issued fresh termination orders on the same reasoning, prompting the appellant to appeal to the Supreme Court.
A bench of the Supreme Court, comprised of Justices Sanjay Karol and Vipul M. Pancholi, allowed the appeal, reinstating his appointment. The Court held that interpreting the eligibility requirement strictly on the basis of the degree’s nomenclature — ignoring the substantive subjects studied — would amount to “elevating form over substance.” The Court reasoned that when the advertised requirement calls for a postgraduate degree in a subject, and the candidate’s actual coursework included the requisite subjects, the literal title of the degree should not be treated as decisive. The Court emphasised that the expression “Postgraduate degree in Statistics” must be understood contextually and purposively; to demand a degree bearing that exact title when no such degree is offered by any recognised university would create an “impossible standard.”
The Court further noted that where a contractual employee’s services are terminated solely on the ground of ineligibility, courts are entitled to examine whether that ground was factually correct and whether relevant material was properly considered. In this case, the candidate’s academic record from the university had been ignored by the inquiry committee. The Court found such disregard by the authorities both unreasonable and arbitrary, amounting to a violation of the candidate’s constitutional right to equality and fair opportunity under Articles 14 and 16.
Accordingly, the Supreme Court quashed the termination orders and restored the appellant to his post, subject to the absence of any other disqualification. This decision underlines that in assessing academic eligibility, what matters is the content of the curriculum and whether it satisfies the functional requirement of the post — not the precise title of the degree. The judgment signals a shift toward a purposive, substance‑oriented evaluation of qualifications in public employment.
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