Allied subject postgraduates cannot be disqualified by retrospectively imposing graduation-level core subject requirements post-advertisement.

The petitioners applied for the post of High School Teacher (Biology) pursuant to an advertisement issued by the respondents.

Despite possessing Post Graduate degrees in "allied subjects" of Biology (such as M.Sc. in Bio-Chemistry or Micro-Biology), the respondents disqualified them.

This disqualification was based on a clarification/circular issued on 10.08.2022—three years after the initial advertisement—stipulating that candidates must possess Biology as a core subject at the graduation level.

The petitioners challenged this disqualification, seeking a direction to treat allied subjects as equivalent to core subjects based on prior executive instructions dated 28.11.2017 and 13.08.2018.

1. Whether the respondents can validly prescribe new eligibility criteria (requiring a core subject at the graduation level) after the selection process has commenced.

2. Whether candidates holding Post Graduate degrees in allied subjects are eligible for appointment to posts advertised for core subjects when both appear for the same competitive examination.

The doctrine that the "rules of the game cannot be changed after the game has started," as affirmed in Smt. Anupriya Kohli vs. The State of Madhya Pradesh and others (WP No. 26051/2022).

The Division Bench precedent in Niharika Shukla and others vs. State of M.P. and others (WP No. 2722/2018), which established that if all candidates appear for the same test in the relevant subject, it constitutes a "level playing field," and candidates with allied subject degrees cannot be disqualified.

Article 226 of the Constitution of India.

The Court reasoned that the circular dated 10.08.2022, which introduced the requirement of having the basic subject at the graduation level, was issued significantly after the advertisement dated 30.12.2019.

Following the precedent in Smt. Anupriya Kohli, the Court held that changing eligibility criteria mid-stream or after the completion of the selection process is legally impermissible.

The Court noted that since all candidates, regardless of whether their degree is in a core or allied subject, sit for the identical recruitment examination, no prejudice is caused to the merit-based selection process.

The Court found the petitioners' situation identical to previous cases where the disqualification for lacking a core subject at the graduation level was set aside.

The Court directed the respondents to consider the petitioners' cases in light of the order in Smt. Anupriya Kohli and, if found eligible, grant them appointment orders for the post of High School Teacher (Biology) within three months.

The petitioners were granted liberty to seek consequential benefits, excluding monetary benefits, effective from the date their peers were appointed.