Higher Qualification Cannot Substitute Mandatory Basic Qualification: Madhya Pradesh High Court

Madhya Pradesh High Court: Justice Anil Verma dismissed a writ petition challenging the rejection of a teaching position application, holding that a Master's degree in English cannot substitute for the mandatory requirement of a Bachelor's degree in English under the Madhya Pradesh School Education Services (Teaching Cadre) Recruitment Rules, 2018. The Court upheld that candidates must possess the specific undergraduate qualification in the subject they intend to teach, regardless of higher qualifications in the same subject.

Background

Lakshmi Kant Sharma, the petitioner, applied for the position of Madhyamik Shikshak (Class-II Teacher) in the subject of English, as advertised by the Madhya Pradesh government. His qualifications included a Bachelor's degree in Political Science, Hindi Literature, and Sanskrit, and an M.A. in English. When his application was rejected on the grounds that he did not meet the required educational criteria, Sharma filed a writ petition challenging this decision. He sought to be declared eligible for the position and requested the quashing of the rejection order passed by the respondent authorities. The petitioner's counsel, Shri Rakshit Gupta, argued that despite his undergraduate degree lacking English as a subject, his Master's degree in English made him eligible for the teaching position. He also contended that other candidates without the necessary qualifications had been appointed to similar positions, further asserting that the refusal to consider him was unjust.

Arguments

Shri Rakshit Gupta, counsel for the petitioner, relied on precedents set by the Central Administrative Tribunal (CAT) in the cases of Intequam Ali v. Government of NCT Delhi and Pooja Devi v. Government of NCT Delhi, arguing that qualifications beyond a Bachelor's degree, such as an M.A., should be considered sufficient in certain cases. The petitioner emphasized his educational achievements in English and contested the exclusion on technical grounds.

On the other hand, the State's counsel underscored that the recruitment rules specifically required a Bachelor's degree in English for the position of Madhyamik Shikshak. Although the petitioner held a Master's degree, his undergraduate degree did not include English as a subject, which disqualified him from the role. Additionally, the respondents rejected the claim that unqualified candidates had been appointed, asserting that those individuals met the necessary criteria.

Court's Reasoning

The Madhya Pradesh School Education Services (Teaching Cadre) Recruitment Rules, 2018, sets the specific criteria for the position of Madhyamik Shikshak (Class-II Teacher) in English. The primary requirement under the rules was a Bachelor's degree in the relevant subject (English) along with a B.Ed. degree. The court emphasized that this requirement was clear and non-negotiable for candidates applying to teach English.

The petitioner, Lakshmi Kant Sharma, had a Bachelor's degree in Political Science, Hindi, and Sanskrit, none of which qualified as a “relevant subject” under the rules. His M.A. in English, while higher in academic standing, did not rectify the absence of a foundational undergraduate degree in English. Recruitment for educational posts requires a solid base in the subject to be taught, which must be demonstrated by continuous, formal study at the undergraduate level. A candidate with no formal undergraduate training in English could not be expected to have the same competence as one who had pursued English as a core subject for three years during their Bachelor's education.

The petitioner argued that he should still be eligible due to his M.A. degree, but the court firmly rejected this stance, holding that postgraduate qualifications could not substitute for the basic educational standards set by the recruitment rules. Justice Verma further reasoned that adhering strictly to the prescribed qualifications ensures fairness and consistency in the selection process, preventing subjective exceptions or relaxed standards that could compromise the integrity of the recruitment.

Additionally, the petitioner's argument that other candidates without proper qualifications had been appointed was found to be unsubstantiated. The court reviewed the records and found that those candidates possessed the necessary qualifications, unlike the petitioner. Thus, the court concluded that deviating from the clear criteria of the recruitment rules would not only undermine the merit-based selection process but also potentially set a dangerous precedent for future recruitments. The court dismissed the petition, stating that Sharma's qualifications were insufficient to make him eligible for the post, and no relief could be granted.

Date: October 18, 2024

Neutral Citation: W.P. No. 30467 of 2024 (Lakshmi Kant Sharma v. The State of Madhya Pradesh)

Citation: 2024 LiveLaw (MP) 270

Counsel for the Petitioner: Shri Rakshit Gupta

Counsel for the Respondent: Shri G.K. Agrawal

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