Authorities must consider relaxation of mandatory qualifications if recruitment rules contain an express discretionary relaxation clause.

The applicants are highly qualified individuals holding Ph.D. degrees and Master’s degrees in various disciplines

They challenged UPSC Advertisement Nos. 11/2025 and 12/2025, and the Recruitment Rules dated 01.10.2024, which prescribed a B.Ed. degree as a mandatory qualification for the post of Lecturer in the School Education Department, UT of Ladakh

The applicants argued that rendering Ph.D. holders ineligible solely for lacking a B.Ed. is arbitrary and discriminatory

They contended that under the previous Jammu & Kashmir rules, B.Ed. was not mandatory for those with higher qualifications and that their superior academic standing should suffice

The Tribunal had previously directed the respondents to consider the applicants' representations, but the respondents maintained that no relaxation was permissible due to NCTE norms

1. Whether the prescription of B.Ed. as a mandatory qualification for Ph.D. holders is arbitrary, discriminatory, or violative of Articles 14 and 16 of the Constitution

2. Whether the possession of a Ph.D. (higher qualification) presupposes the acquisition of a B.Ed. (lower qualification) in the context of school education

3. Whether the respondents are bound to exercise the "relaxation clause" contained in the Recruitment Rules for exceptionally qualified candidates

The court primarily held that the prescription of qualifications falls within the exclusive domain of the employer and expert bodies, and judicial review is restricted unless the criteria are manifestly arbitrary or violative of statutory provisions

Pedagogical training (B.Ed.) and research-oriented qualifications (Ph.D.) are distinct fields with different objectives

The court cited Bedanga Talukdar v. Saifudaullah Khan and State of Tamil Nadu v. G. Hemalathaa to affirm that recruitment must strictly follow prescribed rules

It further noted the statutory role of the National Council for Teacher Education (NCTE) in setting teacher qualifications

The Tribunal analyzed the distinction between subject knowledge (Ph.D.) and the ability to impart it through pedagogical training (B.Ed.), concluding that a higher academic degree does not automatically presuppose the acquisition of teaching methodology required for school education

Consequently, the rule from Jyoti K.K. v. Kerala Public Service Commission regarding higher qualifications was not applied mechanically here

The Tribunal observed that the Recruitment Rules and the advertisements contained an explicit "relaxation clause"

It reasoned that the existence of such a clause implies the rules are not intended to be absolutely rigid and that the competent authority must exercise discretion for meritorious candidates

The court found that the respondents had not objectively considered the applicants' representations in light of this specific relaxation provision

It held that while it cannot substitute its judgment for that of expert bodies, the authorities must consider the applicants' cases under the existing relaxation framework

The Tribunal directed the UPSC and UT Ladakh to consider the applicants for relaxation of the B.Ed. qualification strictly in terms of the relaxation clause by passing a reasoned and speaking order

If the applicants are found deserving of relaxation, the respondents must take steps to enable their participation in the selection process

The OAs were disposed of with no opinion expressed on the final entitlement to relaxation