In a significant ruling on March 20, 2025, the Supreme Court of India, in Civil Appeal No(s). 10389 of 2024, titled Chandra Shekhar Singh and Others v. The State of Jharkhand and Others, held that candidates possessing higher qualifications, such as Master’s degrees, cannot be disqualified from posts requiring only a Bachelor’s degree unless explicitly excluded by the recruitment rules. The decision, delivered by a bench comprising Justice Vikram Nath and Justice Sandeep Mehta, overturned the Jharkhand High Court’s rulings and directed the State of Jharkhand to accommodate the appellants in the recruitment process for Food Safety Officer (FSO) posts initiated in 2016. This judgment reaffirms the principle that higher education enhances, rather than detracts from, eligibility for public employment.
Background of the Case
The dispute traces back to a recruitment notification (Advertisement No. 01/2016) issued by the Jharkhand Public Service Commission (JPSC) on October 7, 2015, inviting applications for FSO positions in Jharkhand. The appellants—Chandra Shekhar Singh and others—held postgraduate degrees in Microbiology, Food Science, and Technology, aligning with the subjects listed in the advertisement. The eligibility criteria required candidates to have “a degree” in fields such as Food Technology, Dairy Technology, Biotechnology, Microbiology, or a Master’s degree in Chemistry, among others, from a recognized university.
The appellants successfully cleared the written examination and were shortlisted for interviews. However, during the recruitment process, JPSC disqualified them, asserting that their Master’s degrees did not satisfy the requirement, which they interpreted as mandating only a Bachelor’s degree in the specified subjects (except for Chemistry, where a Master’s degree was explicitly mentioned). Aggrieved, the appellants approached the Jharkhand High Court, seeking a directive to recognize their qualifications and complete the selection process.
The Single Judge of the High Court dismissed their writ petition on June 30, 2020, and the Division Bench upheld this decision on August 2, 2023, in LPA No. 244 of 2020. Both benches ruled that the appellants’ postgraduate degrees did not meet the advertisement’s criteria, which they interpreted as requiring a Bachelor’s degree for most subjects. The appellants then escalated the matter to the Supreme Court via a special leave petition.
Key Legal Issues
The case hinged on two central legal questions:
- Interpretation of “Degree” in Recruitment Rules: Whether the term “degree” in the JPSC advertisement and the Food Safety and Standards Rules, 2011 (FSS Rules) includes both Bachelor’s and Master’s degrees, or is restricted to the former unless otherwise specified.
- Authority to Prescribe Qualifications: Whether the State of Jharkhand could impose a restrictive interpretation of qualifications for FSO posts, given that the FSS Act vests the Central Government with the exclusive power to prescribe such criteria.
The appellants argued that “degree” should encompass Bachelor’s, Master’s, and Doctorate degrees, as defined under Section 22(3) of the University Grants Commission Act, 1956 (UGC Act), and that excluding higher qualifications was arbitrary. They cited the FSS Act, which assigns the Central Government the authority to set qualifications, and pointed to the 2022 amendment to the FSS Rules explicitly recognizing higher degrees. The respondents countered that the advertisement’s specific mention of a Master’s degree only for Chemistry implied a Bachelor’s degree requirement for other subjects, and that the appellants, having participated without challenging the terms, could not now expand their scope.
Supreme Court’s Decision and Observations
The Supreme Court allowed the appeal, quashing the High Court’s judgments and issuing detailed directions to rectify the appellants’ exclusion. Justice Sandeep Mehta, authoring the judgment, emphasized that higher qualifications cannot be a ground for disqualification unless explicitly barred.
On Interpretation of “Degree”
The Court held that the term “degree” in the FSS Rules and the advertisement must be interpreted in light of Section 22(3) of the UGC Act, which defines it as including Bachelor’s, Master’s, and Doctorate degrees. It rejected the respondents’ restrictive reading, stating:
“There is no logic or rationale behind excluding the candidates having Master’s or a Doctorate degree in these subjects from staking a claim to the post of FSO because such an interpretation would be totally unjust, arbitrary and unconstitutional.”
The Court clarified that the specific mention of a Master’s degree in Chemistry sets a minimum requirement for that subject, but for other listed subjects—such as Microbiology and Food Technology—a candidate with any degree (Bachelor’s, Master’s, or Doctorate) is qualified. It noted the 2022 amendment to the FSS Rules, which explicitly includes higher degrees, as reinforcing this interpretation.
On Authority Under the FSS Act
The Court underscored that Section 37(1) and Section 91(2)(b) of the FSS Act vest the Central Government with exclusive authority to prescribe FSO qualifications. Section 94 limits the State’s rule-making power to operational duties, not eligibility criteria. The Court observed:
“The prescription of qualification for the post of FSO is within the exclusive domain of the Central Government… The FSS Act does not permit the State Government to transgress into the field of prescribing the qualifications.”
This finding invalidated JPSC’s attempt to narrow the eligibility criteria beyond the Central Government’s framework.
Relief Granted
The Court directed:
- The appellants be allowed to participate in the interview stage of the 2016 recruitment process.
- If vacancies are unavailable, supernumerary posts be created to accommodate them.
- Upon selection, they be placed below the last appointed candidate to preserve existing seniority, with notional service benefits but no back wages.
- Their prayer to join the 2023 recruitment process was rejected, as they had not applied under that advertisement.
The Court relied on its precedent in Parvaiz Ahmad Parry v. State of Jammu and Kashmir (2015), affirming that higher qualifications do not render a candidate ineligible for posts requiring lower degrees.
