Madras High Court
Employment and Labour LawAdministrative and Public Law

Candidates holding only Higher Secondary qualifications cannot be disqualified as overqualified for Group IV posts.

MANIVASAGAM.P vs THE REGISTRAR GENERAL,

Madras High CourtJUDGMENT: September 24, 20262 MIN READSOURCE JUDGMENT
Candidates holding only Higher Secondary qualifications cannot be disqualified as overqualified for Group IV posts.. MANIVASAGAM.P vs THE REGISTRAR GENERAL,. Madras High Court. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The petitioner applied under the Madras High Court recruitment notification dated 6 April 2025 for Group IV posts. He had completed Class 10 in 2022 and Higher Secondary (+2) in 2024, and stated that he was not pursuing a higher qualification when he submitted his application in 2025.

Source reference: p. 3–4

After passing the written examination, he was disqualified on the ground that he possessed a higher educational qualification; he had not yet taken the skill test or undergone certificate verification.

Source reference: p. 2–3

He filed a writ petition under Article 226 challenging the disqualification.

Source reference: p. 1–2
02

Issues

Whether the petitioner’s candidature could be rejected as overqualified when he possessed a Higher Secondary (+2) qualification, the maximum qualification specified in the recruitment notification.

Source reference: p. 3–5

Whether the petitioner was eligible under the notification’s undertaking requirement, given that he was not pursuing a qualification higher than Higher Secondary when he submitted his application.

Source reference: p. 4–5
03

Law Applied

The Court applied Clause 4(B) of the recruitment notification, which prescribed a minimum qualification of a pass in Standard VIII, subject to a maximum qualification of Standard XII or its equivalent, and required candidates to undertake that, as of the application date, they were neither possessing nor pursuing a qualification higher than Higher Secondary or its equivalent.

Source reference: p. 3–4

The Court interpreted these as two distinct requirements: a candidate must not possess a qualification above the prescribed maximum and must not be pursuing a higher qualification when applying.

Source reference: p. 4
04

Reasoning

The Court found that the petitioner possessed only the Higher Secondary qualification, which was the notification’s stated maximum, and was not pursuing a higher qualification on the date of his application.

Source reference: p. 4–5

He therefore did not fall within either disqualifying condition identified by the Court. The respondents’ rejection of his candidature as a person possessing a higher educational qualification was consequently inconsistent with Clause 4(B).

Source reference: p. 4–5
05

Holding

The Court allowed the writ petition and set aside the petitioner’s disqualification under the category “Possessing Higher Educational Qualification”.

It directed that he be permitted to participate in the further selection process in accordance with the recruitment notification and applicable service rules; the connected miscellaneous petition was closed, with no order as to costs.

Source reference: p. 5
Madras High Court

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MANIVASAGAM.PvsTHE REGISTRAR GENERAL,

Madras High Court · September 24, 2026

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