In a recent judgment, the Madhya Pradesh High Court, Gwalior Bench, dismissed a writ petition filed by Lakshmi Kant Sharma, a candidate for the post of “Madhyamik Shikshak” (Class-II Secondary Teacher) in English. The petitioner sought to challenge his disqualification for the teaching position based on his academic qualifications. The court, however, upheld the state’s recruitment rules, emphasizing the importance of meeting the specific eligibility criteria set for the advertised position.
Background of the Case
Lakshmi Kant Sharma, a resident of Jhalawar, Rajasthan, filed Writ Petition No. 30467/2024 against the State of Madhya Pradesh and other respondents, challenging the rejection of his application for the post of “Madhyamik Shikshak” in English. He claimed that despite his Master of Arts degree in English, his candidacy was rejected due to his undergraduate qualifications not meeting the stipulated requirements.
The dispute arose from an advertisement issued under the Madhya Pradesh School Education Services (Teaching Cadre) Service Condition and Recruitment Rules, 2018, which outlined the eligibility criteria for various teaching positions, including “Madhyamik Shikshak.” According to these rules, applicants must have a Bachelor’s degree in the relevant subject (in this case, English) along with other qualifications such as a Bachelor in Education (B.Ed.). Sharma argued that he was wrongly excluded from the selection process, while other candidates were allegedly appointed despite similar qualification discrepancies.
Important Legal Issues Involved
1. Eligibility Criteria for Recruitment:
The core legal issue revolved around the interpretation of the minimum eligibility criteria specified in the 2018 recruitment rules for the post of “Madhyamik Shikshak.” The petitioner contested that his M.A. in English should compensate for his lack of an undergraduate degree in English.
2. Consistency in Recruitment:
The petitioner also raised concerns about alleged irregularities, claiming that some candidates were appointed despite not fulfilling the minimum qualification criteria. He contended that his rejection, therefore, constituted unequal treatment, violating the principle of consistency in recruitment.
3. Jurisdiction:
The respondents, represented by Government Advocate Shri G.K. Agrawal, argued that since the petitioner resided in Rajasthan and the impugned order was issued from Bhopal, the matter fell outside the court’s territorial jurisdiction. However, this objection was countered by the petitioner’s counsel, Shri Rakshit Gupta, who pointed out that a previous petition related to this matter had been entertained by the same court.
Court’s Decision and Observations
The case was heard by Justice Anil Verma, who dismissed the petition at the motion stage. The court held that the petitioner did not fulfill the necessary qualifications as per the recruitment rules. Notably, the petitioner’s Bachelor’s degree did not include English as a subject, making him ineligible for the English teaching position.
The court underscored the requirement of consistent study in the subject throughout the undergraduate course as essential for teaching roles. In a significant observation, Justice Verma stated:
“When the post is English Teacher, then it is but natural that the study must be regular basis in graduation of three years in that very subject. The study of that subject through any other mode or a compartmental basis, without regular studies in a bachelor’s course for Arts, can in no way be treated as equivalent.”
This observation highlighted the court’s emphasis on the integrity of subject-specific education for teaching roles, dismissing any notion that subsequent qualifications, like a Master’s degree, could rectify the lack of foundational study in the relevant subject at the undergraduate level.
The court also found no merit in the petitioner’s argument regarding the alleged irregularities in the appointment of other candidates. It concluded that the candidates mentioned by Sharma were, in fact, qualified as per the prescribed criteria, based on records reviewed.
