Santosh B. Naik v. State of Goa & Ors.
Background
The Directorate of Skills Development in Goa advertised posts including Vocational Instructor (Practical) in Plumber, requiring a 10th standard pass under the 10+2 system and a National Trade Certificate. The appellant scored 94 marks in the written examination and the other candidate scored 96. On document verification, the selection committee found that the other candidate did not hold the essential 10th-standard qualification under the 10+2 system, and selected the appellant. The High Court allowed that candidate's writ petition, quashed the committee's minutes, and directed his consideration for the post.
Decision Breakdown
The Supreme Court held that the High Court had erred in interfering with the selection committee's eligibility decision, which was in accordance with the Recruitment Rules for the post and the advertisement. The Court set aside the High Court's judgment, along with the other candidate's later appointment, and restored the committee's decision and the appellant's temporary appointment. It clarified that its conclusion applies only to the Recruitment Rules for this post and expresses no view on the general recognition of NIOS qualifications for other purposes.
Lesson Learnt
Recruitment must follow the qualifications stated in the advertisement and the governing Recruitment Rules. A court will not override a merit-based eligibility decision made under those rules merely because the candidate concerned was higher in the written test.