Determination of educational qualification equivalence is an academic matter beyond the scope of judicial review.

The applicant completed a one-year Broad Based Basic Training (BBBT) course in Process Plant Maintenance and a six-month Advance Module in Mechanical Maintenance of Process Plant

In 2017, the respondents invited applications for 252 posts of Danger Building Workmen (DBW), requiring a National Trade Certificate (NTC) or National Apprentice Certificate (NAC) issued by the NCVT in the trade of Attendant Operator Chemical Plant (AOCP) or Process Plant Operator (PPO)

The respondents rejected the applicant’s candidature on the grounds that he lacked the essential qualification as clarified by the Director General of Training (DGT) in a letter dated 12.10.2018, which specified that equivalence to the AOCP trade required a total of two years of training (one-year BBBT, six-month advanced module, and six-month specialized module)

The applicant challenged this rejection, asserting his qualifications were equivalent

1. What were the requisite certificates and qualifications prescribed for selection to the post of Danger Building Workmen (DBW)?

2. Whether the applicant possessed the mandatory qualifications at the relevant point of time as per the recruitment advertisement?

3. Whether the Tribunal, under judicial review, can determine the equivalency of educational qualifications or expand the ambit of prescribed qualifications?

The court followed the principle that authorities are strictly bound to follow the educational qualifications stipulated in recruitment advertisements

It relied on the Supreme Court ruling in J. Ranga Swamy v. State of A.P., holding that courts cannot consider the relevance of qualifications prescribed for various posts

The principles from Guru Nanak Dev University v. Sanjay Kumar Katwal and Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad were applied, establishing that equivalence of qualifications is a technical academic matter for specialized recruiting authorities and cannot be assumed or declared through judicial review

The court also noted the employer’s prerogative to prescribe eligibility criteria based on job requirements, as reiterated in Unnikrishnan CV v. Union of India

The Tribunal noted that the advertisement explicitly required NAC/NTC in AOCP or PPO trades

A clarification from the DGT dated 12.10.2018 further specified that candidates under the COE Scheme must complete all modules (1 year BBBT + 6 months advanced + 6 months specialized) to be considered equivalent to the 2-year AOCP trade

The applicant only possessed a 1-year BBBT and a 6-month advanced module, failing to meet the full 2-year requirement

The Tribunal observed that the applicant failed to prove his qualification was recognized as equivalent by the Ordnance Factory Board, nor could he rely on DGT letters issued for other departments like the Railways

Applying the 'Rule of Law,' the Tribunal reasoned that it lacks the expertise to sit as an appointing authority or interpret conditions contrary to the plain language of the advertisement

Consequently, since the applicant did not possess the specific certificates required, his exclusion was legally valid

Relying on the precedent set in the similar case of Babi Sahu (OA No. 587/2020), the Tribunal dismissed the Original Application (O.A.) and any pending Miscellaneous Applications (M.A.) without costs