Courts cannot expand allied-subject eligibility absent illegality or manifest arbitrariness.

The petitioners challenged the recruitment advertisement dated 8 September 2026 for Assistant Professor in Zoology insofar as it excluded Biotechnology—and, in the connected petition, Biochemistry—from the listed allied/relevant subjects.

They sought recognition of those subjects for eligibility and, alternatively, provisional participation in the selection process.

Their case relied on academic overlap with Zoology, Biotechnology’s inclusion as an allied subject to Botany in the same advertisement, and its recognition as allied to Zoology in an earlier 2021 recruitment process and subsequent governmental correspondence.

The State and Commission submitted that the impugned list reflected a considered decision of the State Government based on expert recommendations and the applicable regulatory framework.

Whether the exclusion of Biotechnology and Biochemistry from the allied/relevant subjects for Assistant Professor in Zoology was unlawful, arbitrary, or otherwise liable to be set aside.

Whether the petitioners were entitled to provisional participation in the recruitment process notwithstanding that exclusion.

Under the UGC Regulations governing minimum qualifications for academic appointments, eligibility is assessed by reference to the prescribed qualifications, including any relevant or allied subject requirements; the applicable framework and the authority’s determination govern the recruitment in question.

The prescription of qualifications and identification of allied subjects are principally matters for the competent employer and academic or expert authorities.

Judicial review under Article 226 examines legality, not academic merits: a court ordinarily will not substitute its own assessment of equivalence or academic affinity for that of the competent authority, absent a statutory or regulatory conflict, manifest arbitrariness, perversity, mala fides, or reliance on irrelevant considerations.

The Court relied on University of Mysore v. C.D. Govinda Rao, AIR 1965 SC 491; Dr. J.P. Kulshreshtha v. Chancellor, Allahabad University, (1983) 3 SCC 418; Anand Yadav v. State of Uttar Pradesh, (2021) 12 SCC 390; and the Allahabad High Court decisions in Jigyasa Tiwari (Minor) v. State of U.P., 2022 SCC OnLine All 315, Prashant Kumar Jaiswal v. State of U.P., 2017 SCC OnLine All 2919, and Abhinav Tiwari v. State of U.P., 2025 SCC OnLine All 5563.

The Court treated the allied-subject list as a conscious policy determination made by the State Government on expert recommendations, which the Commission incorporated into the advertisement.

The petitioners’ evidence of academic overlap, earlier recognition of Biotechnology as allied to Zoology, and its recognition by another State did not establish that the present decision violated the governing framework or was manifestly arbitrary.

The earlier policy created no immutable entitlement to continued inclusion, and the interim order of the Madhya Pradesh High Court did not determine the merits or bind the Uttar Pradesh authorities.

As the petitioners failed to demonstrate a recognised ground for judicial review, the Court declined both to alter the eligibility criteria and to direct provisional participation.

It clarified that the petitioners could submit relevant material to the competent State Government authority seeking reconsideration of the allied-subject policy; any such representation may be considered on its merits, and the Court expressed no opinion on that question.