Praveen Kumar C.P. v. Kerala Public Service Commission
Background
Two candidates, Praveen Kumar (PK) and P. Anitha Devi (AD), applied for High School Assistant (Natural Science) posts under separate Kerala Public Service Commission notifications. Both had B.Ed. degrees in subjects (Biological Science, etc.) that were not literally the "concerned subject" specified in the recruitment notification, though their degrees were later certified by universities and the State Government as equivalent to the required subject. The Kerala Administrative Tribunal accepted their equivalency and ordered their inclusion in the selection list, but the Kerala High Court reversed this, holding that equivalency granted after the recruitment notification could not be applied retrospectively.
Decision Breakdown
The Supreme Court held that the Government Orders recognising the candidates' B.Ed. degrees as equivalent to the "concerned subject" were merely clarificatory: they confirmed an existing academic status rather than creating a new qualification, so applying them did not amount to impermissibly "changing the rules of the game midway." The Court distinguished this from cases where an entirely new qualification was added to the eligibility criteria after the selection process began. It set aside the High Court's judgments and restored the Tribunal's orders directing that the candidates be included in the ranked list, with consequential appointment benefits if they qualify.
Lesson Learnt
When a government or university formally certifies that a candidate's existing degree is "equivalent" to a qualification required in a job notification, that certification can be treated as confirming a status the candidate always had: it is not automatically barred merely because it was issued after the recruitment process started.