Chief Manager, Punjab National Bank & Anr. v. Anit Kumar Das
Background
Punjab National Bank advertised Peon posts requiring candidates to have passed only up to 12th standard, expressly stating graduates were not eligible. The respondent, though already a graduate since 2014, applied without disclosing this and was provisionally selected and issued an appointment order. During document verification the Bank discovered he was a graduate, found he had suppressed this fact, and cancelled his candidature. He challenged the cancellation in the High Court, which (relying on an Allahabad High Court decision) ruled that a candidate cannot be denied a post merely for holding a higher qualification, and directed the Bank to let him join; a Division Bench upheld this in an unreasoned order.
Decision Breakdown
The Supreme Court held that prescribing "graduates not eligible" for a Peon post was a conscious, considered policy decision taken by the Bank's HR Division since 2008, and that courts should not second-guess an employer's rational recruitment criteria for a given post unless it is shown to be arbitrary. It distinguished the precedent relied on below, noting that case did not lay down a universal rule, and that absent a specific statutory provision equating higher and lower qualifications, a higher qualification cannot be presumed to satisfy a different prescribed qualification. Separately, the Court held that the respondent's deliberate, wilful suppression of his graduate status in his application and bio-data was itself an independent ground justifying cancellation of his candidature. It set aside both High Court orders and allowed the Bank's appeal, though it declined to impose costs given the low-level nature of the post.
Lesson Learnt
Employers, including public sector banks, are entitled to set maximum-qualification caps for certain posts, and courts will generally not interfere with such bona fide policy choices; separately, concealing a material fact (like an excluded qualification) in a job application can validly disqualify a candidate even after provisional selection or appointment.