Higher qualifications cannot substitute mandatory essential qualifications unless expressly permitted by relevant recruitment rules.

The applicants applied for the post of PRT (Music) under Advertisement No. 15/2022 issued by the Kendriya Vidyalaya Sangathan (KVS)

The Recruitment Rules (RRs) and the advertisement required a "Bachelor’s Degree in Music or its equivalent from a recognized University"

All applicants possessed a B.A. degree where Music was an "optional" or "additional" subject, and they subsequently obtained an M.A. in Music

While the applicants cleared the written examination and were issued interview call letters, they were declared ineligible at the interview stage because their undergraduate degrees were not specifically "Bachelor's Degrees in Music"

The applicants challenged Clause (q) of the General Instructions and the rejection of their candidature, citing that similar degrees were accepted in 2014 and that their higher qualification (M.A.) should suffice

1. Whether a B.A. degree with Music as an optional/additional subject fulfills the essential eligibility criteria of a "Bachelor’s Degree in Music" as prescribed under the Recruitment Rules and Advertisement No. 15/2022

2. Whether the possession of a higher qualification (M.A. Music) can substitute or cure the absence of the basic essential qualification (Bachelor’s Degree in Music) in the absence of a specific provision in the Recruitment Rules

3. Whether the respondent's past practice of accepting similar qualifications or the provisional issuance of admit cards creates a vested right or a legitimate expectation for the applicants

The court primarily applied the Recruitment Rules (RRs) for the post of PRT (Music) and the terms of Advertisement No. 15/2022

It relied heavily on the Supreme Court precedent in Zahoor Ahmad Rather & Ors. vs. Sheikh Imtiyaz Ahmad & Ors. (2018), which established that a prescribed qualification is a mandatory threshold and a higher qualification cannot be presumed to include the lower qualification unless the RRs specifically state so

the prescription of eligibility criteria is a matter of recruitment policy within the employer's domain, limiting the scope of judicial review

an erroneous past action cannot be cited as a precedent to perpetuate illegality

The Tribunal found that the Recruitment Rules strictly mandated a "Bachelor’s Degree in Music," whereas the applicants held general B.A. degrees with Music only as an optional subject

Applying Zahoor Ahmad Rather, the Tribunal reasoned that since the RRs did not explicitly recognize a higher qualification (M.A.) as a substitute for the basic UG degree, the applicants' M.A. degrees could not cure the deficiency in their primary eligibility

The court rejected the applicants' plea of discrimination based on the 2014 recruitment, noting that past errors do not create a right to future illegalities

Regarding the denial at the interview stage, the Tribunal held that the recruitment authority maintains the right to verify eligibility at any stage of the process, and the provisional issuance of admit cards does not confer a vested right to appointment if the candidate fails to meet the threshold criteria

It held that the applicants were ineligible for the post of PRT (Music) as they did not possess the mandatory Bachelor's Degree in Music

The court concluded that the respondent’s action was neither arbitrary nor discriminatory, as the eligibility criteria were applied uniformly to all candidates in accordance with the Recruitment Rules

All pending miscellaneous applications were disposed of with no order as to costs