Higher qualification does not disqualify candidates unless recruitment rules specifically exclude overqualified applicants.

The National Institute of Mental Health and Neuro Sciences (NIMHANS) notified 35 posts for Hospital Assistants (Group-C), prescribing a minimum educational qualification of a pass in SSLC

The applicants, possessing SSLC qualifications, participated in an online examination held on 01.10.2023

Following the exam, NIMHANS published a merit list and subsequently shortlisted 35 candidates for a Skill Test

The applicants were not shortlisted as their marks were below the cut-off

They challenged the selection process, alleging that the inclusion of candidates with higher qualifications (e.g., Graduate, B.E., M.Com, M.A.) was violative of Articles 14 and 16 of the Constitution and contrary to Supreme Court precedents, as it deprived SSLC-only candidates of employment opportunities

The Respondents maintained that the Recruitment Rules did not bar higher qualifications and that all selected candidates met the minimum SSLC requirement

1. Whether the inclusion of candidates possessing qualifications higher than SSLC in the selection process for Hospital Assistants is arbitrary, discriminatory, or violative of the Recruitment Rules

2. Whether candidates who participated in the selection process without protest are estopped from challenging the selection criteria after being declared unsuccessful

3. Whether the Tribunal is bound by the judgment of a coordinate bench on an identical set of facts and law

The Tribunal applied the doctrine of Estoppel and Waiver, citing Ramesh Chandra Shah v. Anil Joshi (2013) 11 SCC 309, which held that candidates who participate in a selection process with full knowledge of the rules cannot challenge the methodology after failing

It distinguished the precedents in P.M. Latha v. State of Kerala (2003) 3 SCC 541 and Chief Manager, Punjab National Bank v. Anit Kumar Das (2021) 12 SCC 80, noting that higher qualifications only disqualify a candidate if the recruitment rules or advertisement specifically prohibit them

Furthermore, the Tribunal relied on the Rule of Precedent as established in S.I. Rooplal v. Lt. Governor (2000) 1 SCC 644 and Sant Lal Gupta v. Modern Coop. G.H. Society Ltd. (2010) 13 SCC 336, which mandates that a coordinate bench must follow earlier decisions on similar issues to ensure judicial certainty

The Tribunal reasoned that the Recruitment Rules (C&R Rules) of NIMHANS for the post of Hospital Assistant prescribed SSLC as a "minimum" qualification but contained no express provision disqualifying candidates with higher degrees

The court analyzed the applicants' reliance on PNB v. Anit Kumar Das and found it inapplicable because, in that case, the advertisement had explicitly stated "Graduates are not eligible," whereas no such injunction existed here

The Tribunal further observed that the applicants participated in the entire recruitment process, including the written examination, without any "demur or protest," and only raised the issue of overqualification after realizing they were unsuccessful; this triggered the principle of estoppel

Crucially, the Bench noted that it had already decided an identical challenge in OA No. 457 of 2024 (decided on 28.01.2026), and judicial discipline required following that precedent as the facts and law were indistinguishable

The court concluded that the selection process was conducted strictly in consonance with the laid down procedures and that the applicants had no legal ground to challenge the process after being declared unsuccessful

All pending Miscellaneous Applications were treated as disposed of, and no costs were awarded