Minimum qualification standards set by experts and recruitment rules are not subject to judicial review.

The petitioner participated in the Qualifying Examination 2023 and the subsequent selection test for the post of Primary Teacher (Sports) under the School Education and Tribal Welfare Department

Despite being placed at Serial No. 14 in the general EWS category, the respondents declared him ineligible on May 6, 2026, citing his failure to secure the mandatory 50% marks in the Higher Secondary (Class 12) examination

The petitioner challenged Rule 8(2) and Schedule III, Entry No. 6 of the Madhya Pradesh School Education Service (Teaching Cadre) Service Conditions and Recruitment Rules, 2018 ("Rules 2018"), arguing that since general "Primary Teachers" are allowed a qualification of 45% marks under certain NCTE regulations, the 50% requirement for "Primary Teacher (Sports)" is discriminatory and ultra vires

1. Whether Rule 8(2) read with Schedule III, Entry No. 6 of the Rules 2018 is ultra vires or unconstitutional for requiring 50% marks in Higher Secondary for the post of Primary Teacher (Sports)

2. Whether the Court can substitute its findings or read down the recruitment rules to provide relaxations in minimum educational qualifications

3. Whether a candidate, after participating in a recruitment process and failing, is estopped from challenging the eligibility criteria

The Court applied the principle of judicial restraint in policy matters, asserting that fixing minimum educational qualifications falls strictly within the domain of experts and the employer

It further applied the doctrine of estoppel in recruitment, specifically that a candidate cannot challenge the criteria of a selection process after participating in it and being found unsuccessful

The Court referenced the Madhya Pradesh School Education Service (Teaching Cadre) Service Conditions and Recruitment Rules, 2018, noting that different educational requirements are prescribed for different specialized posts (Science, Music, IT) based on the nature of duties

The Court found the petitioner’s argument regarding discrimination between general Primary Teachers and Sports Teachers to be logically flawed

It reasoned that different posts (such as Science, Music, or Information Technology) entail different duties, necessitating distinct educational qualifications as determined by experts

The Court emphasized that it does not sit as an appellate authority over the wisdom of experts and cannot substitute its own opinion for the prescribed qualifications

Furthermore, the Court observed that the petitioner participated in the recruitment process without protest and only raised the challenge after being declared ineligible, thereby making the petition hit by the principle of estoppel

The Court held that the petitioner is estopped from challenging the rules after having failed the selection process

The writ petition was dismissed as no case was made out for interference