Higher qualification (B.Ed. Special Education) does not automatically substitute a mandatory diploma qualification unless rules expressly state equivalence.

The applicants, Mona Goel and Pravesh Kumari, applied for the post of Special Educator (Primary), Post Code 32/21, under Advertisement No. 01/2021.

They appeared for the written examination on 17.10.2021, scored 88.78 and 88.32 marks respectively, and were shortlisted for the post.

They uploaded their e-dossiers with educational qualifications and caste/EWS certificates within the stipulated period.

Applicant No. 1 held a Diploma in Education and a Bachelor of Education (B.Ed.) in Special Education, while Applicant No. 2 held a Diploma in Education and a Bachelor of Education, Special Education (Mental Retardation), both approved by the Rehabilitation Council of India (RCI).

The Delhi Subordinate Services Selection Board (DSSSB) issued recall notices for deficient documents, which the applicants submitted.

On 01.07.2022, the DSSSB issued Rejection Notice No. 1400, cancelling the applicants' candidatures on the ground that they did not possess the requisite educational qualification of "2 Years diploma in Special Education recognized by RCI or any other equivalent qualification approved by the RCI as per RRs".

The applicants made representations against the rejection, which were not actioned.

The prescribed cut-off date for eligibility conditions was 14.04.2021.

The Recruitment Rules (RRs) for the post specified "2-year diploma programme in Special Education recognized by the Rehabilitation Council of India in any category of Disability or any other equivalent qualification approved by the Rehabilitation Council of India".

The applicants, however, held a generalist Diploma in Education and B.Ed. in Special Education, not a Diploma in Special Education as per the RRs.

Whether the applicants, possessing B.Ed. (Special Education) recognized by the RCI, fulfill the essential qualification of a "2-year Diploma in Special Education recognized by RCI or equivalent qualification approved by RCI" as prescribed under the Recruitment Rules for the post of Special Educator (Primary), Post Code 32/21.

Whether the rejection of the applicants' candidatures vide Rejection Notice No. 1400 dated 01.07.2022 was arbitrary, non-speaking, and violative of principles of natural justice.

Whether possession of a higher qualification (B.Ed. in Special Education) can be treated as equivalent to the prescribed qualification in the absence of an express declaration of equivalence under the Recruitment Rules.

Whether the respondents could have considered subsequent notifications (NCTE Gazette Notification dated 13.10.2021 and DoE Recruitment Rules dated 24.02.2022) for determining eligibility when the cut-off date was 14.04.2021.

The Tribunal applied the principle that recruitment rules must be strictly adhered to and courts cannot rewrite eligibility conditions.

It relied on the Supreme Court judgments in Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad [2026 SCC OnLine SC 88] and Md. Firoz Mansuri and Others v. State of Bihar and Others [2026 SCC OnLine SC 88], which established that higher qualifications do not automatically presuppose lower qualifications unless the rules explicitly state so or equivalence is declared by the competent authority.

The rule of law emphasizes that the employer has the exclusive domain to determine relevant qualifications, and judicial review is limited to examining legislative competence, arbitrariness, or violation of fundamental rights.

Furthermore, the Tribunal reaffirmed the principle that eligibility must be assessed as of the prescribed cut-off date, and subsequent changes in rules or notifications cannot be applied retrospectively ("rules of the game cannot be changed after the game has begun").

The Tribunal found that the applicants did not possess the specific "2-year Diploma in Special Education" required by the Recruitment Rules (RRs) for the post of Special Educator (Primary), Post Code 32/21.

While the applicants held B.Ed. (Special Education) and a generalist Diploma in Education, there was no express declaration by the Rehabilitation Council of India (RCI) or any other competent authority stating that B.Ed. (Special Education) was equivalent to the 2-year Diploma in Special Education for this specific post.

Citing Zahoor Ahmad Rather and Md. Firoz Mansuri and Others, the Tribunal reiterated that a higher qualification cannot automatically substitute a lower, prescribed qualification unless the rules explicitly provide for such equivalence, which was absent here.

Therefore, the applicants did not fulfill the essential qualifications strictly under the RRs.

Regarding the alleged violation of natural justice, the Tribunal noted that the rejection notice, though brief, clearly stated the reason for disqualification, and recall notices had been issued, providing the applicants opportunities to rectify deficiencies.

Since eligibility was objective and document-based, an elaborate personal hearing was not deemed mandatory.

Lastly, the Tribunal determined that the NCTE Notification dated 13.10.2021 and DoE Recruitment Rules dated 24.02.2022, being subsequent to the cut-off date of 14.04.2021, could not be applied to assess the applicants' eligibility.

It reaffirmed the established legal principle that "rules of the game cannot be changed after the game has begun".

It held that B.Ed. (Special Education) could not be considered equivalent to the prescribed diploma in the absence of an express declaration of equivalence by the RCI.

The Tribunal further found no arbitrary action or violation of natural justice, noting that specific reasons for rejection and opportunities for clarification were provided through recall notices.

Finally, it ruled that subsequent notifications and rule changes could not be applied retrospectively to alter eligibility criteria after the prescribed cut-off date.

Consequently, the Original Application was dismissed, being "bereft of merit".

No costs were awarded.