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Kamal Prasad Dubey v. The State of Madhya Pradesh

Civil Appeal · 2026 INSC 353Decided 10 Apr 2026
C.A. No.-004350-004351 - 2026
Justice Prashant Kumar Mishra · Justice N.V. Anjaria · Justice Manoj Misra

Background

The appellant, a long-serving employee of a Primary Agricultural Cooperative Society in Madhya Pradesh, was denied promotion to the post of Society Manager because he lacked the required educational qualification. A Single Judge of the High Court had ordered that he be granted a relaxation in the qualification requirement (as had been given to others in similar situations), but a Division Bench reversed that order, holding the Registrar was within his rights to refuse the relaxation.

Decision Breakdown

The Supreme Court found the Division Bench's reasoning self-contradictory, in one paragraph it said discretion for relaxation lay with the Society's Board of Directors, not the Registrar, yet in another it upheld the Registrar's refusal. The Court held that denying the appellant a relaxation that had been granted to similarly placed employees amounted to unequal treatment violating Articles 14 and 16 of the Constitution. It also noted the appellant had since 2020 acquired the required qualifications on his own. The Court set aside the Division Bench's order and restored the Single Judge's ruling in the appellant's favour, allowing the appeals.

Lesson Learnt

Government and cooperative bodies must apply eligibility relaxation rules consistently, denying a benefit to one employee while granting it to similarly placed employees, without a rational reason, amounts to unconstitutional discrimination under Articles 14 and 16.

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

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