Courts cannot determine equivalence of educational qualifications as it falls within the exclusive domain of experts.

The petitioner, an Assistant Professor holding an M.V.Sc. in Veterinary Epidemiology & Preventive Medicine and a Ph.D. in Veterinary Bacteriology, applied for the post of Associate Professor in Veterinary Medicine at Bihar Animal Sciences University under Employment Notice No. 06/2023.

Despite claiming his Ph.D. research was relevant to the curative management of diseases, he was not called for an interview.

The University’s Screening Committee disqualified him on the grounds that his Ph.D. in "Veterinary Bacteriology" was not a "relevant subject" as prescribed in Clauses 8 and 10 of the advertisement.

The petitioner challenged this exclusion as arbitrary and discriminatory.

1. Whether the petitioner's Ph.D. in Veterinary Bacteriology constitutes a "relevant degree" for appointment to the post of Associate Professor (Veterinary Medicine) under the terms of the specific employment notification.

2. Whether the High Court, under Article 226, can determine the equivalence of academic degrees in specialized technical fields.

The Court applied the principle of judicial restraint in academic matters, holding that the "equivalence of a degree" falls strictly within the domain of expert committees rather than the judiciary.

It relied on University of Mysore v. C.D. Govinda Rao (AIR 1965 SC 491) and Basavaiah (Dr.) v. Dr. H. L. Ramesh (2010 8 SCC 372), which establish that courts should not interfere with the opinions of experts unless there is evidence of malafides.

Per Zonal Manager, Bank of India v. Aarya K. Babu (2019 8 SCC 587), the determination of educational equivalence is a technical question requiring proper assessment of academic standards by expert bodies.

The Court observed that Clauses 8 and 10 of the advertisement explicitly listed the required degrees, including M.V.Sc. in Veterinary Medicine/Preventive Medicine and a "Ph.D. in relevant area".

Upon perusal, the Court found that "Veterinary Bacteriology" was not listed as a relevant subject for the post of Associate Professor in Veterinary Medicine.

The Court rejected the petitioner’s argument that Bacteriology should be subsumed under the broader definition of Epidemiology or Preventive Medicine, stating that such a determination is a technical insight beyond the Court's expertise.

It concluded that the Screening Committee acted within its authority by strictly adhering to the advertisement's criteria, and in the absence of a formal equivalence clarification from a body like the Veterinary Council of India, the petitioner could not claim eligibility.

The Court ruled that the petitioner’s exclusion was neither arbitrary nor illegal based on the plain reading of the recruitment rules.

The dismissal does not preclude the petitioner from approaching the Veterinary Council of India or a competent authority to seek a formal determination of degree equivalence for future recruitment cycles.