In a significant ruling, the Supreme Court of India has reaffirmed that courts should not interfere in appointments when the recruiting authority has accepted the qualifications of selected candidates. The bench comprising Justice Pamidighantam Sri Narasimha and Justice Manoj Misra delivered the verdict in the case of Sajid Khan vs L Rahmathullah & Ors. (Civil Appeal No. 17308 of 2017), allowing the appeals and setting aside the judgment of the High Court.
Background of the Case
The dispute arose from a recruitment process conducted by the Union Territory of Lakshadweep, Department of Electricity for the post of Junior Engineer (Electrical), a Group ‘C’ post. The advertisement for the post required candidates to possess either:
A Degree in Electrical Engineering from a recognized university, or
A Diploma in Electrical Engineering with two years of experience in relevant fields.
The appellants, diploma-holders in Electrical and Electronics Engineering, were selected through the recruitment process conducted by the authorities. However, the respondents, diploma-holders in Electrical Engineering, who were not selected, challenged their appointments before the Central Administrative Tribunal (CAT).
Legal Issues Involved
The main question before the court was whether a Diploma in Electrical and Electronics Engineering could be considered equivalent to a Diploma in Electrical Engineering as per the recruitment rules. The respondents contended that the qualifications of the appellants were not in line with the explicit requirements in the advertisement.
The Central Administrative Tribunal (CAT) ruled in favor of the respondents, holding that unstated qualifications could not be presumed to be acceptable. The Kerala High Court upheld this decision, directing the administration to rework the select list by including only those candidates who met the precise qualifications stated in the advertisement.
Supreme Court’s Observations and Judgment
Reversing the High Court’s ruling, the Supreme Court emphasized that courts should not interfere in appointments when the recruiting authority has accepted the qualifications of candidates. The Court cited several precedents, including Anand Yadav v. State of U.P. (2021), Mukul Kumar Tyagi v. State of U.P. (2020), and Maharashtra Public Service Commission v. Sandeep Shriram Warade (2019), reaffirming that the employer is the best judge of necessary qualifications.
The Court highlighted the clarification issued by the Directorate of Technical Education, Kerala, in 2003, which had already recognized the equivalence of the two diplomas in question. It stated:
“The recruiting authority has scrutinized the qualifications before deciding that they satisfy what is enumerated in the advertisement. It is not the case of the respondents that the authority has not applied its mind in scrutinizing the appellants’ diplomas.”
The judgment further noted that it is the employer’s prerogative to determine equivalency and courts should exercise judicial restraint in interfering with administrative decisions unless there is blatant illegality or arbitrariness.
The Court also referenced Union of India v. Uzair Imran (2023), where it held:
“Normally, it is not the function of the court to determine equivalence of two qualifications. It is entirely the prerogative of the employer to decide whether a candidate is eligible in terms of prescribed rules.”
Key Takeaways from the Judgment
Recruiting authorities have the primary responsibility for determining qualification equivalency.
Courts should refrain from interfering in appointments unless there is evident illegality.
The Lakshadweep administration had already sought and received clarification on the equivalence of qualifications before proceeding with recruitment.
The selected candidates cannot be disqualified merely on the basis of different nomenclature in their diploma certificates.
