Courts cannot substitute expert opinions on candidate eligibility or educational equivalence absent mala fides or patent illegality.

The Petitioner challenged the order dated 23.09.2020 passed by the Central Administrative Tribunal (CAT), which dismissed his challenge to the selection of Respondent No. 3 (R-3) for the post of Regional Director at the National Centre of Organic Farming.

UPSC issued Advertisement No. 12/2015 for five vacancies, specifying educational qualifications including an M.Sc. in Microbiology, Botany, or Agriculture with various specializations (e.g., Horticulture, Soil Science) and ten years of specific research and administrative experience.

R-3 was selected and placed at Serial No. 2, while the Petitioner was placed at Serial No. 1 in the Reserve List.

The Petitioner contended that R-3 lacked the prescribed qualifications, as his M.Sc. was in "Tea Husbandry and Technology" rather than the mandated "Horticulture" or "Soil Science," and that his experience was insufficient.

During proceedings, it was noted the Petitioner had since reached superannuation and the validity of the Reserve Panel had expired.

1. Whether Respondent No. 3 possessed the requisite educational and experience qualifications as stipulated in Advertisement No. 12/2015.

2. Whether the Court can interfere with the technical evaluation and recommendations made by an expert Selection Committee/UPSC in the absence of mala fides.

3. Whether the Petitioner is entitled to substantive relief following his superannuation and the expiry of the Reserve Panel.

The court adhered to the principle that the power of judicial review regarding recommendations of a Selection Committee is extremely limited.

Relying on M.V. Thimmaiah v. UPSC (2008) 2 SCC 119, the court noted that recommendations cannot be challenged except on grounds of mala fides or serious statutory violations, and courts must not act as an appellate authority over expert bodies.

It further applied Dalpat Abasaheb Solunke v. Dr. B.S. Mahajan (1990) 1 SCC 305, which establishes that the fitness of a candidate for a post is a matter for the duly constituted Selection Committee possessing subject-matter expertise, and courts lack the institutional competence to scrutinize relative merits.

The Court observed that while the advertisement listed specific specializations, scientific disciplines often possess overlapping material and are not mutually exclusive.

UPSC clarified that R-3’s M.Sc. in "Tea Husbandry and Technology" included "Soil Science" as a minor subject—an essential qualification—and that R-3 also held a Ph.D. in Horticulture.

Regarding experience, the Court found that R-3’s 15 years in organic tea farming and bio-fertilizers met the 10-year requirement.

The Court emphasized that the Selection Committee, as an expert body, is presumed to understand academic nuances and overlaps in scientific disciplines.

Since no mala fides or arbitrariness were alleged or proven, the Court refused to substitute its own opinion for that of the experts.

Additionally, the Court noted that the Petitioner’s superannuation and the expiry of the 18-to-24-month validity period of the Reserve Panel rendered the prayer for appointment moot.

The Court held that Respondent No. 3 was found eligible by a specialized expert body after due scrutiny of his academic and professional background, and such a decision does not warrant judicial interference unless vitiated by patent illegality or mala fides.

No substantive relief could be granted to the Petitioner as he had reached the age of superannuation and the Reserve Panel was no longer valid.

All pending applications were disposed of.