Case Name: Sahid Khan Vs. L Rahmathullah and Ors.
Case Number: Civil Appeal No. 17308 of 2017
Date: 20 February, 2025
Quorum: Justice Pamidighantam Shri Narasimha
Facts
The Union Territory of Lakshadweep’s Department of Electricity advertised vacancies for the post of Junior Engineer (Electrical) under its recruitment rules. Candidates wanted for the advertisement were obligated to realize a degree in Electrical Engineering or, instead, a Diploma in Electrical Engineering from a government-recognized institution, as well as experience in the related field for two years.
However, the appellants had only a Diploma in Electrical and Electronics Engineering, not a degree, anyway.Prior to the release of the advertisement, the recruiting authority requested clarification from the Directorate of Technical Education, Government of Kerala, which replied that the diploma in Electrical and Electronics Engineering was considered to be equivalent to the Diploma in Electrical Engineering. On the basis of this clarification, the authority released a select list in which the appellants were included.
Respondents contested that the appellants’ qualifications did not precisely match the advertised requirement, leading to proceedings before the Central Administrative Tribunal (CAT) and subsequently the High Court, both of which set aside the appellants’ selection.
Issues
- Whether a Diploma in Electrical and Electronics Engineering should be considered equivalent to the Diploma in Electrical Engineering as prescribed in the recruitment advertisement?
- The appropriate scope for judicial review in recruitment matters, particularly in determining whether technical differences in qualifications should invalidate an otherwise reasoned decision of the recruiting authority?
Legal Provisions
Lakshadweep Electricity Department (Group ‘C’ and ‘D’ Technical Posts) Recruitment Rules, 2002: Specifies that candidates for the post of Junior Engineer (Electrical) must possess either a Degree in Electrical Engineering from a recognized university or a Diploma in Electrical Engineering from a recognized institution with two years of relevant experience in one of the specified fields.
Arguments of the Appellants
The appellants argued that their diploma in Electrical and Electronics Engineering is largely identical with the specified Diploma in Electrical Engineering but with the added subject.
They pointed out that the recruiting authority had voluntarily sought a clarification from the Directorate of Technical Education, Government of Kerala, that the two diplomas were equivalent.
Relying on this official explanation and technical similarity in syllabus, curriculum, and duration, they contended that there was no material difference which ought to disqualify their choice.
Arguments of the Respondents
The respondents assured that the ad clearly demanded a Diploma in Electrical Engineering and insisted that any discrepancy from this requisite qualification could never be assumed tolerable.
They contended that the recruitment rules did not make any provision for any implied equivalence among various titles of diplomas, and that the recruiting authority must go by the express language of the advertisement.
To them, accepting candidates with varying nomenclatures would be in violation of the clear requirements and establish an unequal selection process.
Analysis
The Court scrutinized cautiously the recruitment rules, the clarification letter issued by the Government of Kerala, and the arguments presented by both sides.
The recruitment agency had taken a deliberate step to estimate the equivalence of qualifications before going ahead with advertising, which is evident from letters written to the Directorate of Technical Education. The explanation, issued as far back as 2003, stipulated that the diploma of Electrical and Electronics Engineering would be considered equal to the specified diploma of Electrical Engineering in the educational system of the state.
The Court underlined that the duty to decide on the candidates’ fitness is largely in the hands of the recruiting authority, who is more capable of interpreting technical qualifications.
Based on established precedents, the Court emphasized the judicial restraint doctrine and declared that the courts should not intervene in recruitment decisions if the employer’s decision is rational, adequately informed, and grounded on technical evidence.
Judgment
Following a thorough scrutiny of the facts and legal norms, the Supreme Court held that the decision of the recruiting authority to equate the Diploma in Electrical and Electronics Engineering with the Diploma in Electrical Engineering was rational and justified. The Court reserved the High Court decision that had disqualified the appellants since there was no cogent reason to override the judgment of the authority concerning qualifications. The decision maintained that, in cases of disputed equivalence, the onus lay with the respondents to establish a material distinction between qualifications, which they failed to do.
Conclusion
The ruling reiterates the doctrine that recruitment choices, especially on the issue of equivalence of qualifications, should be upheld if based on cogent, well-informed judgments. Referring to the reserved ruling of the High Court that barred the appellants, it was observed that there was no compelling reason to override the evaluation conducted by the competent body concerning qualifications.
The judgment affirmed that the burden of showing a substantial difference in qualifications lay with the respondents in the case of conflicting equivalence, which they failed to discharge. Therefore, the decisions made by the UT of Lakshadweep’s Department of Electricity stand affirmed, placing stress on due process and judicial deference in recruitment issues.
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