Chhattisgarh High Court
Employment and Labour LawAdministrative and Public Law

A post-selection equivalence certificate cannot retrospectively cure eligibility defects or reopen the recruitment process.

RITESH DHIDHI vs STATE OF CHHATTISGARH

Chhattisgarh High CourtJUDGMENT: September 08, 20263 MIN READSOURCE JUDGMENT
A post-selection equivalence certificate cannot retrospectively cure eligibility defects or reopen the recruitment process.. RITESH DHIDHI vs STATE OF CHHATTISGARH. Chhattisgarh High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner applied pursuant to Advertisement No. 07/2025/Exam for direct recruitment to the post of Assistant Director (Planning) and qualified in the written examination. His candidature was rejected at document verification because the nomenclature of his Master’s degree did not correspond with the qualification prescribed in the advertisement, and he was consequently not permitted to appear in the interview

Source reference: p.1–2, para. 1

After the interview and publication of the final selection list on 12.05.2026, the petitioner obtained an equivalence certificate from the Academic Council of Pt. Ravishankar Shukla University on 28.07.2026, certifying that his degree was equivalent to the prescribed qualification.

Source reference: p.2–4, paras. 1, 5–6

He sought quashing of the rejection and a direction for a special interview.

Source reference: p.2–4, paras. 1, 5–6

The PSC opposed the claim, relying on the advertisement’s requirement that candidates establish eligibility before submitting applications and that documents submitted after the last date would not be considered.

Source reference: p.2–3, para. 2

The petitioner also contended that no appointment orders had yet been issued to the selected candidates.

Source reference: p.1–2, para. 1
02

Issues

Whether an equivalence certificate issued after the interview and publication of the final selection list could retrospectively cure the petitioner’s deficiency in educational eligibility

Source reference: p.4–5, paras. 6–7

Whether the petitioner was entitled to a special interview and consideration of his candidature despite the completed selection process and the terms of the advertisement

Source reference: p.5–6, paras. 8–10

Whether the principle concerning deference to a competent academic authority’s determination of equivalence, as relied upon from Laxmikant Sharma v. State of Madhya Pradesh & Ors. , applied in the circumstances of the case

Source reference: p.5–6, para. 9
03

Law Applied

The Court applied the terms of the recruitment advertisement, including the requirement that candidates satisfy themselves regarding the prescribed educational qualification before submitting their applications and the stipulation that documents would not be considered after the last date.

Source reference: p.3–4, para. 4

It applied the principle that eligibility must be established at the stage prescribed by the recruitment process and that a subsequent document cannot ordinarily be used to reopen a selection process that has culminated in publication of the final selection list.

Source reference: p.4–6, paras. 6–10

The Court considered Laxmikant Sharma v. State of Madhya Pradesh & Ors. , 2025 INSC 1385, but distinguished it on the ground that the equivalence certificate in the present case was issued only after completion of the interview and publication of the final selection list.

Source reference: p.5–6, para. 9
04

Reasoning

Although the Academic Council was competent to certify equivalence, its certificate was issued only on 28.07.2026, after the interview had been conducted and the final selection list had been published on 12.05.2026.

Source reference: p.4–5, paras. 5–6

Under the advertisement, the petitioner was required to establish his eligibility at the application or, at the latest, document-verification stage. Since no equivalence had been established before the recruiting authority at the relevant stage, the subsequent certificate could not retrospectively cure the deficiency.

Source reference: p.4–5, paras. 6–7

The absence of appointment orders did not create a right to reopen the concluded selection process, and granting a special interview would have allowed the petitioner to participate on the basis of a qualification established only after the selection process had substantially concluded.

Source reference: p.5, para. 8

Accordingly, Laxmikant Sharma did not assist the petitioner because the issue was not the academic authority’s power to determine equivalence, but the impermissibility of relying on a belated determination to reopen the recruitment process.

Source reference: p.6, para. 9
05

Holding

The Court held that the equivalence certificate dated 28.07.2026 could not be relied upon to invalidate the rejection of the petitioner’s candidature or to compel the respondents to conduct a special interview.

The writ petition was dismissed.

Source reference: p.6, para. 11
06

Acts & Sections Cited

1 provisions across 1 statute referred to in this judgment. Each provision opens on LawLens.

Prohibition of Electronic Cigarettes (Production, Manufacture, Import, Export, Transport, Sale, Distribution, Storage and Advertisement) Act, 20191

Chhattisgarh High Court

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RITESH DHIDHIvsSTATE OF CHHATTISGARH

Chhattisgarh High Court · September 08, 2026

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