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Zonal Manager, Bank of India, Zonal Office, Kochi v. Aarya K. Babu

Civil Appeal · 2019 INSC 882Decided 8 Aug 2019
Civil Appeal No. 6206 of 2019
Justice R. Banumathi · Justice A.S. Bopanna

Background

A recruitment notification issued by the Institute of Banking Personnel Selection for the post of Agricultural Field Officer required a degree in "Agro-Forestry." The private respondents (including Aarya K. Babu, provisionally selected by Bank of India, and another candidate selected by Syndicate Bank) held degrees in "Forestry" instead, and their selections were cancelled for not meeting the prescribed qualification. The Kerala High Court's Single Judge and then Division Bench had ruled in the candidates' favour, holding that "Forestry" was equivalent to "Agro-Forestry," prompting the banks to appeal to the Supreme Court. Since both appeals raised the identical question and had been disposed of by the Kerala High Court through a common order, the Supreme Court heard and decided them together.

Decision Breakdown

The Supreme Court held that courts should not substitute their own view on equivalence of educational qualifications for that of the recruiting authority, relying on the Constitution Bench ruling in Mohammad Shujat Ali vs. Union of India. Since "Forestry" was only later added as an equivalent qualification by a corrigendum issued after the selection process had concluded, that later inclusion could not retrospectively validate candidates who did not hold the originally required qualification. The Court therefore set aside the High Court's judgments and allowed both appeals, while clarifying this would not disturb similarly-qualified officers already continued in service elsewhere. However, invoking its special Article 142 power to do complete justice, the Court directed Bank of India to separately give Aarya K. Babu a fresh appointment as Agricultural Field Officer (without back benefits), citing her personal hardship: an exception made clear not to be treated as a precedent.

Lesson Learnt

Courts generally defer to expert recruiting bodies on technical questions like equivalence of educational qualifications, and a later relaxation of eligibility criteria does not retroactively benefit candidates who failed to meet the original criteria, though the Supreme Court can still grant individualized relief in deserving cases using its special constitutional powers.

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

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