A degree does not impliedly replace a diploma prescribed as an essential qualification.

The Petitioners challenged the BMC’s advertisement dated 25 November 2024 for Junior Engineer (Civil) and Junior Engineer (Mechanical and Electrical) posts.

They sought permission for engineering graduates who did not hold the prescribed diploma to apply, arguing that a degree was a higher qualification.

The 2023 Recruitment Rules specified a three-year engineering diploma as the educational qualification for direct recruitment.

On 11 December 2024, a Co-ordinate Bench directed the BMC to allow engineering graduates to apply, subject to the outcome of the petition.

Diploma-holder candidates challenged that interim order before the Supreme Court, which stayed its operation and later requested the High Court to decide the petition within eight weeks.

Whether an engineering degree, without the prescribed diploma, satisfies the eligibility requirement for the Junior Engineer posts

Whether the advertisement was consistent with the 2023 Recruitment Rules and the Government Resolution relied on by the Petitioners

Whether limiting eligibility to candidates holding the prescribed diploma violated Articles 14 and 16 of the Constitution

The 2023 Recruitment Rules prescribed a three-year diploma in the relevant engineering discipline for direct recruitment to the Junior Engineer posts.

The Court applied the principle that the employer determines the relevance and suitability of qualifications for a post, and that judicial review of such choices is limited to examining legislative competence, arbitrariness, or violation of fundamental rights; courts cannot rewrite service rules or substitute their assessment for that of the employer.

It also relied on Firoz Mansuri for the proposition that a qualification in one stream does not necessarily establish possession of a different prescribed qualification, and that prescribing a diploma requirement is not arbitrary merely because degree-holders may have other employment opportunities.

Articles 14 and 16 prohibit arbitrary discrimination, but do not require an employer to treat a degree as equivalent to a diploma where the employer has prescribed the diploma as essential.

The Court read the Rules as making the diploma—not a general level of engineering education—the essential eligibility qualification.

Rule 4(B), which treats engineering degree and diploma holders as having computer knowledge, addressed only that separate requirement and did not extend eligibility for the post.

The Model Recruitment Rules did not assist the Petitioners because they had not been adopted by the Corporation.

Nor did the Government Resolution displace the 2023 Rules, which the Court treated as governing the recruitment.

Applying Firoz Mansuri, the Court declined to infer that a degree automatically included or superseded a diploma.

It held that determining the qualification suited to the post lay within the employer’s domain and found no basis to conclude that the diploma requirement was arbitrary or unconstitutional.

It dismissed the petition, disposed of the interim applications, permitted the BMC to complete the recruitment process forthwith, and made no order as to costs.