North Delhi Municipal Corporation v. Kavinder
Background
The North Delhi Municipal Corporation advertised the post of Labour Welfare Superintendent, requiring a postgraduate degree/diploma in Social Work, Labour Welfare, Industrial Relations, Personnel Management, or an allied subject. Kavinder, who held an MBA degree, applied and was provisionally shortlisted after the written exam but was later declared ineligible. He challenged this before the Central Administrative Tribunal, which, and later the Delhi High Court, ruled that studying subjects like Human Resource Management and Industrial Relations during his MBA satisfied the eligibility criteria.
Decision Breakdown
The Supreme Court disagreed, holding that merely studying a couple of related subjects as part of a general MBA programme does not amount to holding a postgraduate degree or diploma specifically in the disciplines named in the advertisement, or in an "allied subject." The Court held that the employer, not the courts, is best placed to judge equivalence of qualifications unless that judgment is shown to be perverse, which it was not here. The Tribunal and High Court were held to have erred, the appeal was allowed, and the direction to appoint Kavinder was set aside.
Lesson Learnt
Courts generally defer to an employer's assessment of whether a candidate's qualifications meet a recruitment criterion, unless that assessment is clearly unreasonable: simply having studied a related topic within a broader degree does not automatically satisfy a specific educational eligibility requirement.