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Service & Administrative LawSupreme Court of India

Chandra Shekhar Singh v. The State of Jharkhand

Civil Appeal · 2025 INSC 372Decided 20 Mar 2025
C.A. No.-010389-010389 - 2024
Justice Vikram Nath · Justice Sandeep Mehta

Background

The appellants, holding post-graduate (Master's) degrees in subjects like microbiology and food technology, applied for the post of Food Safety Officer under a 2015-16 Jharkhand Public Service Commission recruitment, where the advertised eligibility required "a Degree" in specified science subjects. After clearing the written exam, they were disqualified before interview on the ground that a Master's degree could not be treated as a valid qualifying "degree" for the post. Their writ petition and subsequent intra-court appeal before the Jharkhand High Court were both dismissed, even though the University Grants Commission itself had filed affidavits stating that "degree" should include both Bachelor's and Master's degrees in the relevant subjects.

Decision Breakdown

The Supreme Court held that restricting "degree" to only a Bachelor's degree, while excluding candidates with a Master's or higher degree in the very same qualifying subjects, would be unjust, arbitrary and unconstitutional: a more qualified candidate should not be shut out on a technical reading of the rules. It noted that the Central Government itself later amended the Food Safety and Standards Rules in 2022 to expressly clarify that Bachelor's, Master's, or Doctorate degrees in the specified subjects all qualify, confirming the appellants' reading was correct all along. The Court set aside both High Court judgments, held the appellants were qualified, and directed that if vacancies did not exist, the State create supernumerary posts to let the appellants participate in interviews from the stage they were wrongly disqualified, with any resulting appointment effective from the original 2016 select list date (for seniority) but without back wages, and ranked below already-selected candidates to protect their settled seniority.

Lesson Learnt

A "degree" requirement in a job qualification should ordinarily be read to include higher degrees (Master's, Doctorate) in the same subject unless the rules clearly and specifically restrict it to a Bachelor's degree only, excluding better-qualified candidates on a hyper-technical reading is arbitrary and can be struck down.

Chandra Shekhar Singh v. The State of Jharkhand – Legal Case Shots | LegalAware