A Pharmacy degree cannot satisfy prescribed subject-wise eligibility absent recognized equivalence.

Kunal Gogna was provisionally nominated on merit in the OBC category for TGT (Natural Science) (Male), Post Code 35/21.

During verification, the Directorate of Education found that he held a Bachelor of Pharmacy degree but did not meet the subject-wise qualification prescribed by the Recruitment Rules and Advertisement No. 02/21. An Expert Committee concluded that he had not studied the prescribed main subjects for the required two years or four semesters during graduation; his candidature was cancelled on 23 February 2024.

Gogna relied, among other things, on an institute’s certificate stating that he had studied Chemistry and Biology during all three years of his course. At the interim stage, the Tribunal recorded a prima facie view in his favour and considered his request to reserve a post, but later clarified that the interim observations were not a final determination of eligibility.

He sought to have the cancellation set aside and to be appointed with consequential benefits.

1. Whether Gogna’s Bachelor of Pharmacy qualification and the subjects he studied satisfied the prescribed subject-wise educational qualification for TGT (Natural Science) (Male), Post Code 35/21.

2. Whether the Tribunal should interfere with the Directorate’s cancellation of his candidature following the Expert Committee’s assessment.

The applicable Recruitment Rules and Advertisement No. 02/21 required study of a prescribed main subject—Physics, Chemistry, Biology, Botany or Zoology—for at least two years during graduation.

The Tribunal relied on the principle that equivalence of educational qualifications is a technical matter for the competent authority or expert body; courts and tribunals ordinarily defer to that assessment unless it is arbitrary, perverse, mala fide or contrary to the governing rules. It also adopted the authorities discussed in its earlier decision, including Mohammad Shujat Ali v. Union of India (1975) 3 SCC 76, J. Ranga Swamy v. Government of Andhra Pradesh (1990) 1 SCC 288, State of Rajasthan v. Lata Arun (2002) 6 SCC 252, Guru Nanak Dev University v. Sanjay Kumar Katwal (2009) 1 SCC 610, Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad (2019) 2 SCC 404, and Devender Bhaskar v. State of Haryana, Civil Appeal No. 7031 of 2021, decided 24 November 2021.

A qualification’s general degree-level equivalence, or the study of some relevant subjects, does not itself establish compliance with a specific subject-and-duration requirement.

The Tribunal treated the Expert Committee’s assessment as addressing the specific requirement in the Recruitment Rules, rather than the general academic standing of a Bachelor of Pharmacy degree. Although Gogna relied on evidence that he had studied Chemistry and Biology, the Committee concluded that he had not studied the prescribed main subjects for the required duration; he produced no material showing that his degree was recognised as equivalent for this recruitment under the applicable rules or a binding order.

Applying the principle of deference to expert assessments of equivalence, and its earlier decision concerning eligibility for the same post, the Tribunal found no basis to displace the Committee’s conclusion. It also held that the favourable observations made at the interim stage did not determine his eligibility on the merits.

The Original Application was dismissed; pending miscellaneous applications were disposed of, with no order as to costs.