Functional equivalence of educational qualifications prevails over strict nomenclature variations in recruitment rules.

The applicant, holding a Bachelor of Engineering in Mechanical and Production Engineering, applied for the post of Junior Engineer (JE) in the Electricity Department and JE (EM) in the Port Blair Municipal Council (PBMC) following a 2023 recruitment notice.

The essential qualification for the Electricity Department was a "Degree in Electrical/Mechanical/Electrical Electronics Engineering".

While the applicant secured rank 18 in the merit list, the respondents rejected his candidature for the Electricity Department, asserting his degree did not strictly match the notified branches.

Notably, in a 2018 recruitment for the same post with identical qualifications, the respondents had initially rejected but subsequently accepted the applicant's degree after scrutiny, though he failed that year on merit.

Following a previous Tribunal order (O.A. 1379/2023) directing re-verification, the respondents issued a Speaking Order on 29.12.2023 again rejecting the claim, citing strict adherence to Recruitment Rules (RR) and a 2010 DoPT OM.

1. Whether the applicant’s degree in "Mechanical and Production Engineering" satisfies the essential qualification of a degree in "Mechanical Engineering" for the post of Junior Engineer.

2. Whether the respondents are barred from rejecting the applicant's qualification in 2023 after having accepted the same qualification for the same post in 2018-2019.

3. Whether the applicant's failure to challenge the Admit Card (which only listed him for the PBMC post) prior to the examination precluded his claim for the Electricity Department post.

Recruitment guidelines under DoPT OM No. AB.14017/48/2010-Estt. (RR) dated 31.12.2010, which instructs departments to specify educational qualifications precisely and avoid the term "or equivalent" when framing Recruitment Rules.

The principle of administrative consistency, holding that an authority cannot adopt divergent stands on the same eligibility criteria across different recruitment cycles without a "plausible reason".

The principle that technical degrees should be assessed based on curriculum and university certification of equivalence rather than mere nomenclature.

The Tribunal found the respondents' rejection arbitrary and inconsistent. It noted that the essential qualifications in 2018 and 2023 were identical.

Since the respondents had accepted the applicant's Mechanical and Production Engineering degree in 2019 after detailed scrutiny, their reversal in 2023 lacked a satisfactory explanation.

The Tribunal rejected the respondents' reliance on the 2010 DoPT OM, clarifying that while the OM guides the framing of rules to be specific, it does not prohibit the recognition of equivalent degrees during implementation, especially when the issuing university confirms such equivalence.

Regarding the procedural delay, the Tribunal held that the applicant’s failure to object to the Admit Card entry was not a "serious enough lapse" to forfeit his right to be considered for a post for which he was otherwise meritorious and qualified.

The court emphasized that in a diversified educational system, it would be a "travesty" to exclude candidates based purely on nomenclature without regarding the underlying curriculum.

The Tribunal directed the respondents to appoint the applicant as a Junior Engineer in the Electricity Department within 90 days. It further ordered that existing appointments should not be disturbed and that a supernumerary post must be created if necessary to accommodate the applicant. The OA was disposed of with no costs.