Candidate eligibility must be reconsidered in light of the Equivalence Committee’s report.

The petitioner, possessing an M.Sc. in Agriculture Science (Plant Pathology), applied pursuant to the Uttarakhand Public Service Commission’s advertisement dated 10.08.2021 for the Uttarakhand Combined State Civil/Upper Subordinate Services Examination, 2021, which included the posts of Mushroom Development Officer and Plant Protection Officer.

Although he participated in the preliminary examination and was declared successful for the post of Mushroom Development Officer, he was treated as academically ineligible for appointment as Plant Protection Officer.

In Khushboo Kholia v. State and Others, WPSB No. 219 of 2022, a Co-ordinate Bench directed constitution of an Expert Committee to examine equivalence of the relevant academic qualifications.

The Equivalence Committee subsequently found the petitioner educationally qualified for the post of Plant Protection Officer.

Nevertheless, the Commission rejected his candidature by orders dated 26.04.2024 and 12.07.2024, relying on a State Government letter dated 13.05.2022, which indicated that a degree in Agriculture Science with specialization in Entomology alone could be considered for the post.

Whether the Commission was justified in rejecting the petitioner’s candidature for the post of Plant Protection Officer by relying on the State Government’s letter dated 13.05.2022 despite the subsequent report of the Equivalence Committee finding him educationally qualified.

Whether the rejection orders dated 26.04.2024 and 12.07.2024 were sustainable when they failed to consider the report of the Equivalence Committee.

The Court applied the principle that an administrative authority must consider and give due effect to the material determination made by a duly constituted expert committee, particularly where the committee was constituted pursuant to an earlier judicial direction to examine equivalence of educational qualifications.

The Court further held that an earlier administrative communication concerning educational eligibility could not retain controlling relevance after the Equivalence Committee had submitted its report on the issue.

No specific statutory provision or additional judicial precedent was relied upon in the order.

The Court found substance in the petitioner’s contention that the Equivalence Committee’s report superseded the relevance of the State Government’s earlier letter for determining his eligibility.

Since the Committee had examined the equivalence question pursuant to the Court’s earlier direction and had found the petitioner educationally qualified, the Commission was required to consider that report.

The impugned orders were legally deficient because they were silent regarding the Committee’s findings and instead relied upon the letter dated 13.05.2022.

The rejection orders dated 26.04.2024 and 12.07.2024 were set aside insofar as they concerned the petitioner.

The Secretary of the Uttarakhand Public Service Commission was directed to reconsider the petitioner’s eligibility in light of the Equivalence Committee’s report and pass a fresh order within three weeks from the date of presentation of a certified copy of the judgment.

If the petitioner was found eligible and otherwise suitable, the Commission was directed to make an appropriate recommendation to the State Government in accordance with law.