New Delhi: The Supreme Court has ruled that when a candidate has studied the requisite subject as a principal component of their postgraduate curriculum, their candidature cannot be rejected merely because the degree title does not bear that subject’s name, holding that insisting solely on degree nomenclature amounts to elevating form over substance.
The Bench of Justice Sanjay Karol and Justice Vipul M. Pancholi delivered the decision while allowing an appeal filed by Laxmikant Sharma challenging the Madhya Pradesh High Court’s order, which had upheld the termination of his contractual services as Monitoring and Evaluation Consultant with the Water Support Organization, State Water Mission, Public Health & Engineering Department.
The case arose from an advertisement issued by the department prescribing the minimum qualification as “Postgraduate degree in Statistics from a Government recognised University with at least 60% marks or equivalent grade.” The appellant held an M.Com. (Commerce) degree from a government college affiliated to Dr. Harisingh Gour University, Sagar, completed in 1999. As part of his curriculum, he had studied Business Statistics and Indian Economic Statistics as principal subjects.
After verification of his educational qualifications and experience, the appellant was appointed on contract on April 26, 2013, and joined service on May 16, 2013. He served for nearly one year. Subsequently, an eight-member Committee submitted a report on September 24, 2013, stating that the appellant did not possess the required qualification for the post. Relying on this report, his services were terminated on October 10, 2013.
In successive litigation, the High Court set aside the termination orders on multiple occasions and directed the authorities to reconsider the matter after granting the appellant a fair opportunity. During reconsideration, two significant documents emerged:
- a certificate dated March 30, 2019, issued by the appellant’s college/university stating that his M.Com. degree included Business Statistics as a principal subject; and
- an opinion dated November 23, 2019, issued by the Director of the department stating that the appellant did possess the requisite Statistics components in his postgraduate curriculum and recommending restoration of his services.
Despite these documents, the State again terminated the appellant’s services by orders dated November 2, 2018, and May 14, 2020, reiterating that he lacked the requisite qualification. Both the Single Bench and Division Bench of the High Court upheld the termination on the ground that the appellant did not possess a “degree in Statistics” as prescribed.
The appellant argued before the Supreme Court that the High Court ignored the undisputed fact that no government university in Madhya Pradesh offers a postgraduate course titled “M.Com. (Statistics)” or any PG degree bearing “Statistics” in its nomenclature. Interpreting the eligibility criteria to require a degree that does not exist in any government university, he contended, is arbitrary and unrealistic. He further argued that the eight-member Committee did not give him an opportunity to be heard, violating natural justice, and that the Director’s expert opinion certifying his eligibility was wrongly disregarded.
The State argued that the advertisement explicitly required a postgraduate degree in Statistics with minimum 60% marks, and that the appellant’s M.Com. degree, which merely included statistical subjects, could not be treated as a Master’s degree in the discipline of Statistics. Citing Supreme Court precedents, the State submitted that courts cannot expand the scope of prescribed qualifications or deem a non-prescribed qualification equivalent, and that contractual employment does not confer a right to continuation.
The Supreme Court held that the core issue was the interpretation of the qualification “postgraduate degree in Statistics” and whether the State’s decision satisfied standards of fairness and non-arbitrariness.
The Court noted that it was undisputed that no government university in Madhya Pradesh offers a postgraduate course titled “M.Com. (Statistics)” or any standalone postgraduate programme exclusively titled “Statistics.” In these circumstances, insisting solely on the title of the degree without examining the curriculum amounts to elevating form over substance. The expression must, therefore, be construed contextually and purposively.
The Court acknowledged precedents stating that questions of equivalence fall primarily within the domain of the employer or expert bodies, and that courts should not ordinarily interfere. However, it held that the present case stood on a different footing: the appellant was not seeking equivalence with another qualification but asserting that he satisfied the prescribed criteria when interpreted reasonably.
The Court identified two major infirmities in the Committee’s report: first, the subsequent university certificate established that the appellant had studied Business Statistics as a principal subject, rendering the Committee’s conclusion objectively incorrect; second, the Committee arrived at its findings without giving the appellant an opportunity to be heard, violating natural justice.
The Court held that continued reliance on this flawed report, without evaluating relevant documents, rendered subsequent termination orders arbitrary, uninformed, and unsustainable in law.
The Court emphasized that the Director’s letter dated November 23, 2019, issued after examining the appellant’s marksheets and curriculum, clearly stated that the appellant satisfied the eligibility requirements and recommended continuation of service. The Director noted that the appellant’s degree included Quantitative Methods, Business Statistics, and Economic Statistics—statistical subjects certified by the university—and that he had served satisfactorily for nearly one year with no adverse remarks.
The Court held that once the competent authority had taken a considered view supporting eligibility, the State gave no valid reason to disregard that expert opinion.
The Court also observed that other candidates possessing degrees with Statistics as principal subjects were appointed and continued in service, and the State provided no rational basis to distinguish the appellant from similarly qualified persons. The Court rejected the State’s reliance on “negative equality,” holding that the appellant was not seeking parity with unqualified persons but asserting that he was similarly situated with those found eligible. Arbitrarily singling him out violated Article 14.
On the nature of contractual employment, the Court relied on GRIDCO Ltd. v. Sadananda Doloi, reiterating that even when the State acts in a contractual sphere, it remains bound by Article 14 obligations of fairness and non-arbitrariness. When a contractual employee is terminated solely on the ground of ineligibility, courts may examine whether that ground is factually correct and based on relevant material.
The Court concluded that once it was established that the appellant had studied Statistics as principal subjects and the competent authority had certified his eligibility, the State’s contrary stand was arbitrary and unreasonable. Despite repeated remands, the authorities failed to conduct a fair reconsideration.
Setting aside the High Court’s judgment, the Supreme Court held that the appellant possessed the requisite academic qualification when interpreted reasonably in light of the advertisement and relevant circumstances. It directed that the appellant, if otherwise eligible, be restored to service within four weeks with all consequential benefits.
The Court clarified that the judgment was rendered in the specific facts of the case and should not be treated as a precedent.
Case Title: Laxmikant Sharma v. State of Madhya Pradesh & Ors.
(Civil Appeal arising from SLP(C) No. 18907 of 2025)
