Devender Bhaskar v. State of Haryana
Background
The Haryana Staff Selection Commission advertised posts for Arts and Crafts teachers, requiring a two-year diploma in Art and Craft from the Haryana Industrial Training Department or an "equivalent qualification" recognized by the Haryana Education Department. A group of candidates who held a similar diploma obtained through distance/correspondence education from Kurukshetra University were rejected, as the State did not treat that diploma as equivalent, prompting them to challenge the rejection in the High Court. The High Court ruled in favour of the candidates, holding they had a legal right to be considered using their Kurukshetra University diploma, and the Haryana-recognized diploma holders (who stood to be affected) appealed to the Supreme Court.
Decision Breakdown
The Supreme Court examined detailed evidence, including government meeting minutes, departmental correspondence, and even a caution notice issued by Kurukshetra University itself, showing that the university's distance-education diploma was a different, less rigorous course (fewer practicals, no regular classroom training, no merit-based admission) than the department's regular diploma, and that the university itself had never claimed the two were equivalent or guaranteed any job through it. Relying on precedent that equivalence of qualifications is a technical matter for the recruiting authority's experts to decide, and that courts should not lightly interfere with such assessments unless they are irrational, the Court found the High Court had wrongly treated the two diplomas as equivalent. It therefore set aside the High Court's judgment and dismissed the underlying writ petitions.
Lesson Learnt
Courts will generally defer to a government department's expert assessment of whether one educational qualification is truly "equivalent" to another prescribed qualification, and will not override that judgment unless it is shown to be arbitrary, irrational, or based on irrelevant considerations.