Equivalence of academic qualifications and recruitment policy are beyond the scope of judicial review.

The Petitioner applied for the post of Assistant Professor (Zoology) under the OBC category following Advertisement No. 51/2022 issued by the Madhya Pradesh Public Service Commission (MPPSC).

After qualifying for the written examination, the Petitioner was provisionally selected. However, upon document scrutiny, the MPPSC rejected his candidature via notification dated 08.09.2025, later supplemented by a corrigendum dated 14.10.2025.

The rejection was grounded on the fact that the Petitioner possesses M.Sc. (Agriculture) in Entomology and a NET certificate in Agriculture Entomology, rather than the required Master's degree in Zoology (or its 11 recognized allied subjects) and NET in Life Sciences.

The Petitioner challenged this, arguing that Entomology is a cognate branch of Zoology and the rejection was hyper-technical.

1. Whether the respondents were justified in rejecting the candidature of the petitioners on the ground that they did not possess the prescribed Post Graduate Degree in the main or allied subjects and the NET certificate in the requisite subject

The prescription of educational qualifications and the determination of "equivalence" of degrees are matters of recruitment policy and academic expertise.

The precedent set in Zahoor Ahmad Rathor v. Sheikh Imtiyaz Ahmad (2019) 2 SCC 404 establishes that judicial review cannot be used to expand the ambit of prescribed qualifications or substitute the court’s view for that of the employer.

A recruitment agency is bound by the specific terms of the advertisement to ensure compliance with Article 14 and 16 of the Constitution of India.

The Court reasoned that it cannot act as an "appellate academic body" because constitutional courts lack the specialized expertise to assess degree equivalence.

The Higher Education Department (HED) had issued specific orders on 22.12.2022 delineating core and allied subjects, and an independent expert committee had reviewed the petitioners' documents before concluding they were ineligible.

The Court found that the Petitioner’s degrees (Agriculture Entomology) did not match the mandatory requirement of Zoology or its 11 specified allied subjects.

The Court dismissed the Petitioner’s reliance on SET-2024 notifications or UGC Regulations, noting that NET/SET are merely qualifying exams and do not override the State's right to prescribe specific eligibility criteria tailored to service needs.

Deviating from the advertisement’s terms mid-process would constitute a "fraud on the public" by prejudicing those who did not apply based on the advertised rules.

The Court concluded that the petitioners had no vested right to claim eligibility contrary to statutory stipulations and that the expert committee’s decision suffered from no procedural or constitutional infirmity.

The writ petitions were dismissed, and no order as to costs was made.