Diplomas from Unrecognized Institutions are not Equivalent to a Degree in Fine Arts from a Recognized University.

The Appellant applied for the post of Trained Graduate Teacher (TGT), Art, in Eklavya Model Residential Schools (EMRS) managed by Respondent No. 1 (NESTS).

The required essential qualification was a "Degree in Fine Arts/Crafts from a recognized University".

The Appellant holds diplomas (Chitra Bhushan and Chitra Visharad) from Pracheen Kala Kendra, Chandigarh, which he claimed were equivalent to a Bachelor of Fine Arts (BFA).

Although initially shortlisted and issued a provisional appointment offer on 02.03.2024, NESTS later cancelled the appointment via email on 24.06.2024, citing ineligibility due to lack of essential qualifications.

The Appellant challenged this via a Writ Petition, which was dismissed by a Single Judge on 26.03.2025.

The present Letters Patent Appeal (LPA) was filed against said dismissal.

Whether the diploma qualifications held by the Appellant qualify as a "Degree in Fine Arts/Crafts from a Recognized University" as per the recruitment criteria.

Whether NESTS is bound to follow the recruitment patterns of Navodaya Vidyalayas or the equivalence certifications issued by the diploma-granting institution itself.

The Court applied Section 2(f) of the University Grants Commission (UGC) Act, 1956, defining a "University".

It relied on Section 22 of the UGC Act, which restricts the right to confer degrees to recognized Universities or deemed institutions.

It relied on the principle that the determination of "equivalence" of educational qualifications is the exclusive domain of the employer, as established in Mukul Kumar Tyagi v. State of U.P. (2020) and Zahoor Ahmad Rather v. Imtiyaz Ahmed (2019).

It noted the UGC’s 2001 Model Curriculum, which distinguishes between professional BFA streams and general streams.

The Court reasoned that Pracheen Kala Kendra does not meet the statutory definition of a "recognized university" under the UGC Act.

Consequently, the diplomas issued by it cannot be treated as "degrees" under Section 22 of the Act.

The Court rejected the Appellant's argument on equivalence, stating that an institution cannot unilaterally certify its own diplomas as equivalent to a university degree to bind an employer.

Regarding the provisional appointment letter, the Court held that since it was subject to document verification, NESTS was entitled to cancel it upon discovering the qualification variance.

The Court emphasized that judicial review cannot expand to deciding equivalence unless the employer’s decision is proved to be arbitrary or unreasonable, which was not the case here.

The Court held that NESTS is not bound by the Navodaya Vidyalaya pattern nor the Appellant's internal equivalence certifications.

The division bench concurred with the Single Judge’s judgment, dismissed the appeal, and upheld the cancellation of the Appellant's appointment.