Unnikrishnan CV and Others vs. Union of India and Others
Background
The appellants were employees of the General Reserve Engineer Force who had been appointed as Overseers/Surveyor Draughtsmen between 1977 and 1986 and were later promoted to Superintendent BR Grade-II after completing a government-sponsored Diploma in Draughtsman Estimating and Design (DED) from the College of Military Engineering, Pune. They sought further promotion to the higher post of Superintendent BR Grade-I, which under the applicable recruitment rules required a "Diploma in Civil Engineering," not the DED diploma they held. The High Court rejected their claim, and they appealed to the Supreme Court.
Decision Breakdown
The Supreme Court held that the recruitment rules clearly and specifically required a Diploma in Civil Engineering for promotion to Superintendent BR Grade-I, and the appellants admittedly held a different diploma (DED) instead. It rejected the appellants' argument that their diploma should be treated as equivalent, holding that equivalence of qualifications is a technical academic and administrative matter that only the concerned rule-making or expert body can declare. Courts cannot assume or impose such equivalence on their own. Since no notification or rule recognized DED as equivalent to a Civil Engineering diploma, the appeal was dismissed.
Lesson Learnt
Courts will not create or assume equivalence between different educational qualifications for promotion purposes. If a recruitment rule specifies a particular qualification, only the employer or the relevant academic/administrative authority (not the judiciary) can determine whether a different qualification counts as equivalent.