B.Tech. qualifications do not satisfy TGT Natural Science requirements absent recognized subject-wise equivalence under recruitment rules.

The applicants challenged the cancellation of their candidature for the post of Trained Graduate Teacher (TGT) (Natural Science), Female, Post Code 36/21, advertised by the Delhi Subordinate Services Selection Board under Advertisement No. 02/21 dated 12 May 2021.

The advertisement required a Bachelor’s degree or equivalent qualification with 45% marks in two school subjects, including a prescribed Natural/Physical Science subject—Physics, Chemistry, Biology, Botany or Zoology—studied at the elective level and for at least two years during graduation.

Jyoti Vyas possessed a B.Tech. in Electronics and Communication and was declared successful in the SC category; after issuance of deficiency memoranda and an offer of appointment, her candidature was ultimately cancelled by order dated 8 February 2024 on the ground that she had not studied any prescribed main subject for the required duration.

Priyanka Verma possessed a B.Tech. in Electrical & Electronics and similarly claimed that Physics had been studied for two years during graduation.

Both applicants relied on NCTE norms, syllabus similarities, institutional clarifications, and alleged appointments of similarly qualified candidates.

The respondents relied on the opinions of two Expert Committees, which concluded that the applicants did not satisfy the subject-specific educational qualification.

1. Whether the applicants’ B.Tech. qualifications in Electronics/Electrical & Electronics were equivalent to the prescribed graduation qualification for appointment as TGT (Natural Science), particularly where the Recruitment Rules required study of Physics, Chemistry, Biology, Botany or Zoology for at least two years during graduation.

2. Whether the applicants could rely on NCTE norms, syllabus similarities, university or institutional clarifications, and alleged appointments of similarly situated candidates to establish eligibility contrary to the applicable Recruitment Rules.

3. Whether the Tribunal should interfere with the Expert Committees’ conclusion that the applicants had not studied any prescribed main subject for the requisite period.

The Tribunal applied Section 19 of the Administrative Tribunals Act, 1985, under which the Original Applications were filed.

The applicable Recruitment Rules governed eligibility and specifically required study of one of the prescribed Natural/Physical Science subjects—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 and academic matter ordinarily to be determined by the competent authority or an expert body, and courts should not interfere unless the decision is arbitrary, perverse, irrational, mala fide, or contrary to the governing rules.

This principle was drawn from 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; and Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad, (2019) 2 SCC 404.

The Tribunal also relied on Prakash Chand Meena v. State of Rajasthan, (2015) 8 SCC 484, and Government of NCT of Delhi v. Paramjit Kaur, SLP(C) No. 1112/2018, holding that equivalence must be recognised under the applicable rules or governmental orders existing before commencement of recruitment and cannot be created by judicial assessment during the recruitment process.

NCTE norms concerning eligibility for admission to B.Ed. programmes could not amend or expand the Recruitment Rules applicable to appointment as TGT (Natural Science).

The Tribunal held that the question was not merely whether a B.Tech. degree could generally be treated as a Bachelor’s degree or equivalent qualification, but whether the applicants’ particular degrees satisfied the subject-specific requirement for teaching Natural Science.

The applicants’ reliance on Physics and Electronics-related syllabus content, the assertion that Electronics is a sub-discipline of Physics, and clarifications issued by individual institutions did not establish that Physics or another prescribed subject had been studied as a main subject for at least two years in the manner required by the Recruitment Rules.

The NCTE provision relied upon concerned admission to B.Ed. courses and had no effect on the recruitment qualifications for the post in question.

The applicants’ candidatures had been considered by duly constituted Expert Committees comprising subject experts, and the Committees concluded that none of the candidates had studied a prescribed main subject for the requisite period.

Since the applicants could not identify any pre-existing rule, notification, or binding order recognising their specific B.Tech. qualifications as equivalent for this subject-specific recruitment, and no arbitrariness or perversity was demonstrated, the Tribunal declined to substitute its view for that of the experts.

Alleged appointments of similarly qualified candidates could not create a right to perpetuate an erroneous or irregular appointment contrary to the Recruitment Rules.

It held that their B.Tech. qualifications were not shown to satisfy the prescribed subject-wise eligibility requirement for TGT (Natural Science), and that the Expert Committees’ conclusions and the consequential cancellation of candidature disclosed no illegality warranting interference.

O.A. Nos. 1467/2024 and 1564/2024 were dismissed; all pending miscellaneous applications, if any, were also disposed of, with no order as to costs.