CAT - ['Chennai']
Employment and Labour LawAdministrative and Public Law

Essential qualifications prescribed by recruitment rules cannot be relaxed for individual candidates.

K SEKAR vs M/o Railways

CAT - ['Chennai']JUDGMENT: September 02, 20263 MIN READSOURCE JUDGMENT
Essential qualifications prescribed by recruitment rules cannot be relaxed for individual candidates.. K SEKAR vs M/o Railways. CAT - ['Chennai']. LawLens
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicants, residents of Puducherry, were qualified for appointment as Guest Trained Graduate Teachers (English).

Source reference: para. 2

The respondents initially issued separate region-wise recruitment notifications for Puducherry, Karaikal, Mahe and Yanam.

Source reference: paras. 6–7

Following objections to the regional restrictions, a comprehensive notification dated 5 July 2019 was issued for the entire Union Territory.

Source reference: paras. 6–7

However, the notification required candidates applying for a particular region to possess knowledge of that region’s language as an essential qualification: Tamil for Puducherry and Karaikal, Malayalam for Mahe, and Telugu for Yanam.

Source reference: paras. 6–7, 12

The applicants, who had not studied Telugu, challenged the requirement insofar as it applied to the Yanam-region vacancies and sought permission to participate without satisfying the regional-language condition.

Source reference: para. 1

During the proceedings, the Tribunal permitted them to participate provisionally, directing that their results be kept in sealed cover and that any appointment remain subject to the outcome of the OA.

Source reference: para. 11

The third applicant was subsequently appointed and was serving as a Guest Trained Graduate Teacher.

Source reference: para. 14
02

Issues

Whether the requirement that a candidate possess knowledge of the regional language, including Telugu for vacancies in the Yanam region, was liable to be set aside as discriminatory and violative of Articles 14, 15, 16 and 21 of the Constitution.

Source reference: paras. 1, 3–5

Whether the Tribunal could permit the first and second applicants to participate in the selection and obtain appointment by relaxing or dispensing with the regional-language qualification prescribed under the Recruitment Rules.

Source reference: paras. 12–14

Whether the appointment of the third applicant, who had already been appointed and was continuing in service, should be disturbed.

Source reference: paras. 14–15
03

Law Applied

The Tribunal applied the applicable Recruitment Rules, under which knowledge of the concerned regional language was an essential qualification for appointment as a Trained Graduate Teacher.

Source reference: paras. 7–8, 12

It relied on P.U. Joshi v. Accountant General, Ahmedabad, (2003) 2 SCC 632, for the principle that prescription of qualifications and service conditions falls within the domain of the Government and that courts or tribunals should not compel the authority to tailor qualifications to individual candidates.

Source reference: para. 9

It further relied on Rajasthan Public Service Commission v. Lavanshu Sankhla, 2026 INSC 444, holding that where the governing rules and advertisement require a candidate to “possess” an essential qualification, that qualification cannot be relaxed or indirectly dispensed with; what cannot be done directly cannot be achieved indirectly.

Source reference: para. 13

The Tribunal also recognised the constitutional challenge raised under Articles 14, 15, 16 and 21, but ultimately decided the matter on the basis that the regional-language requirement was an unchallenged essential qualification under the Recruitment Rules.

Source reference: paras. 3, 8, 12–14
04

Reasoning

The Tribunal found that the regional-language condition in the modified notification merely reflected the qualification already prescribed by the Recruitment Rules and was not an additional or arbitrary restriction introduced through the notification.

Source reference: paras. 6–8, 12

The requirement was considered rationally connected with the duties of a teacher, since knowledge of the regional language facilitated communication with students in the concerned region.

Source reference: para. 12

As the first and second applicants sought to participate without possessing an essential qualification, granting their request would amount to relaxing or dispensing with the Recruitment Rules, which the Tribunal held it could not do in light of Lavanshu Sankhla.

Source reference: para. 13

The Tribunal therefore rejected their claim for participation and appointment without the regional-language qualification.

Source reference: para. 14

However, because the third applicant had already been appointed and was continuing in service, the Tribunal directed that her appointment should not be disturbed, subject to the applicable rules and law.

Source reference: paras. 14–15
05

Holding

The Tribunal rejected the first and second applicants’ prayer to participate in the recruitment process without possessing the prescribed regional-language qualification, holding that an essential qualification under the Recruitment Rules could not be relaxed by the Tribunal.

It directed that the third applicant, who had already been appointed, be permitted to continue as Guest Trained Graduate Teacher, subject to the applicable rules and law.

Source reference: paras. 14–15

The Original Application was accordingly disposed of, all pending Miscellaneous Applications were closed, and there was no order as to costs.

Source reference: para. 16
CAT - ['Chennai']

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K SEKARvsM/o Railways

CAT - ['Chennai'] · September 02, 2026

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