An NIOS Secondary Certificate does not satisfy a post’s specific 10th-standard-under-10+2 eligibility requirement.

The Goa Directorate of Skills Development and Entrepreneurship advertised a post of Vocational Instructor (Practical), Plumber, requiring candidates to have “passed 10th standard under 10+2 system of education,” in addition to specified trade qualifications and experience.

In the written examination, Respondent No. 3 scored 96 marks and the appellant scored 94.

On document verification, the Departmental Selection Committee found Respondent No. 3 ineligible because his Secondary School Certificate was obtained through the National Institute of Open Schooling (NIOS), and selected the appellant.

The High Court allowed Respondent No. 3’s writ petition, treating his NIOS qualification as satisfying the academic requirement.

The appellant challenged that decision before the Supreme Court.

1. Whether a Secondary School Certificate obtained through NIOS satisfies the requirement of having “passed 10th standard under 10+2 system of education” under the applicable Recruitment Rules.

2. Whether the High Court could treat the NIOS qualification as meeting that specific requirement on the basis of its general recognition or equivalence.

Recruitment qualifications must be satisfied as prescribed, and a court ordinarily cannot add to or alter essential eligibility criteria; whether a qualification is equivalent to the prescribed qualification is ordinarily for the employer or competent expert body, as stated in Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad (2019) 2 SCC 404, Unnikrishnan C.V. v. Union of India (2023) 18 SCC 546, and Shifana P.S. v. State of Kerala (2024) 8 SCC 309.

The text of a qualification must be construed in context, and each part of its wording must be given effect; Reserve Bank of India v. Peerless General Finance & Investment Co. Ltd. (1987) 1 SCC 424.

Prescribing essential qualifications falls within the employer’s domain, and courts should not substitute their view where the Rules and advertisement are clear; Maharashtra Public Service Commission v. Sandeep Shriram Warade (2019) 6 SCC 362.

General recognition of a qualification does not, by itself, amend or enlarge a post-specific eligibility requirement.

The Court treated the words “under 10+2 system of education” as an integral part of the prescribed qualification, rather than as surplusage.

The Recruitment Rules contained no provision deeming a recognised or equivalent NIOS certificate to satisfy that specific condition; accordingly, general recognition of the NIOS certificate did not establish compliance with the post’s eligibility criteria.

The Department’s prior application of the same interpretation in the 2015 recruitment process supported the consistency of its approach, though it was not treated as binding precedent.

Respondent No. 3’s higher examination score could not cure the failure to meet an essential qualification.

It set aside the High Court’s judgment and Respondent No. 3’s appointment, restored the Committee’s decision selecting the appellant, and restored the appellant’s temporary appointment, subject to the applicable service terms.

The appeal was allowed.