Candidates possessing integrated M.Sc.-B.Ed. qualifications cannot be denied interview solely due to course structure.

The applicants had applied for recruitment to the post of Post Graduate Teacher (PGT—Chemistry) pursuant to Advertisement No. 15/2022 issued by the Kendriya Vidyalaya Sangathan (“KVS”).

They possessed Integrated M.Sc.–B.Ed. qualifications in Chemistry from the Central University of Rajasthan and claimed that their qualifications satisfied the applicable eligibility requirements.

After appearing in the written examination and being shortlisted for interview, the applicants were declared ineligible during document verification and were not permitted to participate in the interviews scheduled at Bhubaneswar from 15 to 17 May 2023.

The applicants relied upon a communication dated 17 May 2023 from the Central University of Rajasthan stating that its Integrated M.Sc.–B.Ed. programmes were approved by the National Council for Teacher Education (“NCTE”), as well as an earlier appointment offered by KVS to a similarly situated candidate possessing the same or comparable qualification.

KVS contended that the Recruitment Rules prescribed a specific two-year Integrated Post-Graduate M.Sc. course of the Regional College of Education, NCERT, and that the applicants’ three-year Integrated M.Sc.–B.Ed. qualification could not automatically be treated as equivalent.

During the proceedings, an application for withdrawal by one applicant was dismissed as withdrawn with liberty to file afresh; the Tribunal confined the order to the applicants who remained before it.

Whether the applicants could be denied participation in the PGT (Chemistry) interview solely because they possessed an Integrated M.Sc.–B.Ed. qualification rather than the specific qualification relied upon by KVS.

Whether the question of equivalence and eligibility ought to have been finally determined before permitting the applicants to participate in the interview, or whether their suitability should first have been assessed through the selection process.

Whether the applicants were entitled to a direction requiring KVS to conduct their interviews and reconsider their candidature in accordance with the applicable Recruitment Rules.

The Tribunal applied the eligibility requirements contained in the applicable KVS Recruitment Rules and Advertisement No. 15/2022, while considering the recognition and regulatory approval of the applicants’ Integrated M.Sc.–B.Ed. qualifications by the Central University of Rajasthan and NCTE.

It applied the principle that eligibility and suitability are distinct concepts: where a candidate claims to possess the prescribed or equivalent qualification and produces supporting documents, the candidate should not ordinarily be excluded from the selection process without the competent selection authority assessing the claim in accordance with the governing rules.

The Tribunal also relied upon the Coordinate Bench decision in Anooj Kumar v. KVS, concerning consideration of integrated qualifications under the PGT Recruitment Rules.

The Tribunal also took note of Geeta Rani v. KVS, concerning denial of an opportunity to participate in an interview for a PGT post.

The Tribunal found that the applicants had already cleared the written examination and had been shortlisted for interview, but were excluded at the document-verification stage solely on the respondents’ interpretation of the prescribed qualification.

The materials produced by the applicants—including their qualification certificates, the University’s communication confirming the structure and NCTE approval of the Integrated M.Sc.–B.Ed. programme, and the uncontroverted appointment offered to a similarly situated candidate—raised a bona fide issue regarding recognition and equivalence of the qualification.

In these circumstances, the Tribunal held that the applicants’ suitability should have been assessed through the interview process and that the dispute concerning eligibility or equivalence should be dealt with by the duly constituted selection authority under the applicable Recruitment Rules.

The temporary nature of the posts did not justify denying consideration of the applicants’ candidature.

Without expressing any final opinion on their entitlement to appointment, the Tribunal concluded that they deserved an opportunity to participate in the interview.

KVS was directed to conduct interviews of the applicants in accordance with the applicable Recruitment Rules and the relevant selection process within two months from receipt of a certified copy of the order.

KVS was further directed to pass a reasoned and speaking order after completing the exercise and supply it to the applicants.

If the decision was favourable, consequential benefits were to be extended within 45 days thereafter.

Pending miscellaneous applications were disposed of, with no order as to costs.