Higher or different qualifications do not satisfy prescribed eligibility requirements absent recognised equivalence.

The applicants in the connected Original Applications had applied pursuant to Kendriya Vidyalaya Sangathan’s Advertisement No. 15/2022 for appointment as Trained Graduate Teacher (TGT—Art Education).

They appeared in the Computer Based Test conducted on 13.02.2023, qualified according to the applicable cut-off, and were issued interview letters.

However, when they appeared at Kendriya Vidyalaya No. 1, Salt Lake, Kolkata, for interviews scheduled between 18.05.2023 and 22.05.2023, they were not permitted to participate because the respondents considered their qualifications—principally a three-year B.A. with Drawing/Painting or Fine Arts as a subject, followed by an M.A. in Drawing and Painting/Visual Arts—not equivalent to the prescribed qualification.

The prescribed qualification was a five-year recognised Diploma in Drawing and Painting/Sculpture/Graphic Art or an equivalent recognised degree, along with working knowledge of Hindi and English.

The applicants alleged that their qualifications were equivalent, relied on earlier appointments and the seniority list of TGT (Art Education), and contended that denial of interview after issuance of interview letters was arbitrary and violative of Articles 14 and 16 of the Constitution.

The respondents maintained that application acceptance, examination participation, shortlisting, and issuance of interview letters were provisional and subject to document verification; the applicants had failed to produce documentary proof of equivalence.

1. Whether the applicants’ B.A. and M.A. qualifications in Drawing and Painting, Fine Arts, Visual Arts, or related disciplines satisfied the prescribed qualification of a five-year recognised Diploma in Drawing and Painting/Sculpture/Graphic Art or an equivalent recognised degree for appointment as TGT (Art Education).

2. Whether possession of a higher or postgraduate qualification could, by itself, cure the absence of the specific essential qualification prescribed under the Recruitment Rules.

3. Whether the respondents acted unlawfully or arbitrarily in refusing to permit the applicants to participate in the interview despite their having qualified the written examination and received interview letters.

4. Whether prior appointments of candidates with allegedly similar qualifications, including the appointment relied upon by the applicants, created a right to parity or participation in the present recruitment process.

The Tribunal applied the Recruitment Rules prescribing a “Five Years’ recognized Diploma in Drawing and Painting/Sculpture/Graphic Art OR Equivalent recognized Degree” and working knowledge of Hindi and English.

It held that essential qualifications prescribed by the employer must be strictly satisfied and that the employer is ordinarily the competent authority to determine the relevance, suitability, and equivalence of qualifications.

Relying on Md. Firoz Mansuri v. State of Bihar, 2026 INSC 68, it reiterated that courts cannot rewrite recruitment rules, determine equivalence, or substitute their assessment for that of the recruiting authority, absent arbitrariness or perversity.

The Tribunal also relied on Govt. of NCT of Delhi v. Manu, which held that a facially higher qualification does not necessarily satisfy a prescribed qualification in the relevant discipline.

Rajesh Kumar v. National Education Society for Tribal emphasised that a candidate for a subject-teacher post must possess at least a bachelor’s degree in that subject and that studying it only as an additional subject may be insufficient.

Arvind Kumar v. U.T. Chandigarh held that equivalence is an expert determination and that a postgraduate qualification cannot cure the absence of the prescribed basic qualification.

The Tribunal further relied on Kanchan v. KVS and Renu Sharma v. KVS regarding verification of qualifications at the document-verification stage.

The Tribunal found that the applicants had not established, through documentary or external material, that their B.A. and M.A. qualifications were equivalent to the prescribed five-year recognised Diploma or equivalent degree.

It distinguished between possessing a higher qualification and possessing the specific foundational qualification required for the post.

In particular, a B.A. in which Drawing and Painting or Fine Arts was merely one of the subjects did not demonstrate the depth and breadth of study expected for teaching the subject as a TGT, and an M.A. in Drawing and Painting could not retrospectively supply the missing prescribed qualification.

The applicants’ success in the written examination and receipt of interview letters did not create an indefeasible right to interview because their candidature remained subject to eligibility verification under the advertisement.

The Tribunal also rejected reliance on earlier appointments and the seniority list, holding that eligibility had to be assessed under the Recruitment Rules applicable to Advertisement No. 15/2022 and that prior appointments, even if based on similar qualifications, could not override the present statutory requirements.

The decision in Nidhi Rani v. Department of School Education and Literacy was held inapplicable and per incuriam in the context of the applicable statutory provisions.

It held that the applicants had neither possessed nor established equivalence with the essential qualification prescribed for TGT (Art Education), and that the respondents were justified in rejecting their candidature at the verification stage and refusing interview participation.

All connected Original Applications were dismissed as devoid of merit.

Pending miscellaneous applications, if any, were also dismissed, and there was no order as to costs.