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Council of Architecture v. Mr. Mukesh Goyal & Ors.

Civil Appeal · 2020 INSC 298Decided 17 Mar 2020
Civil Appeal No. 1819 of 2020
Dr. Justice D.Y. Chandrachud · Justice Ajay Rastogi

Background

An employee of NOIDA (a Uttar Pradesh development authority), who did not hold a recognised degree in architecture, was working in a post that NOIDA's own service rules titled "Architect"/"Associate Architect." The Council of Architecture, the statutory body that registers qualified architects under the Architects Act, 1972, argued that Section 37 of that Act, which restricts use of the title "architect" to those registered under it, barred both the unqualified practice of architecture and the use of that title by anyone not registered, including in government posts, and challenged NOIDA's promotion rules that allowed this.

Decision Breakdown

The Supreme Court held that Section 37 of the Architects Act does not prevent unregistered individuals from actually practising architecture-related work, but it does prohibit anyone, including a government employee, from holding a post that uses the title "Architect" or "Associate Architect" unless they are registered under the Act, because that title creates a reasonable assumption that the holder has the statutorily recognised qualifications. Since NOIDA's own promotion rules (made under a state law) conflicted with this central statute, the central law had to prevail. The appeals were partly allowed: NOIDA was told it could continue promoting whoever it wished to perform the job, but it must rename any post using the word "architect" if the person holding it is not registered under the Architects Act.

Lesson Learnt

A professional designation protected by a central law, like "Architect," "Doctor," or "Advocate", cannot be used as an official job title for someone who isn't actually registered under that law, even by a government employer, because the public is entitled to assume the title means the person meets the legal qualification.

Official source (sci.gov.in)View Judgment (PDF)

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