Portal non-configuration cannot defeat legally recognized equivalence of Fauquania to Class X.

The applicants challenged their inability to apply online for engagement to posts under the Gramin Dak Sevak (GDS) cadre pursuant to the Department of Posts’ notification dated 18.09.2017.

The notification prescribed Matriculation/Class X qualification from an approved or recognised Board

Both applicants possessed Fauquania certificates issued by the Bihar State Madrasa Education Board, which they asserted were equivalent to Class X and recognised for Central Government employment.

However, the Bihar State Madrasa Education Board was not available in the online application portal’s list of educational Boards, preventing them from submitting their applications

The respondents contended that the applicable GDS qualification required a Secondary School Examination/Class X pass certificate and that, pursuant to Postal Directorate instructions dated 14.01.2015 and 16.06.2017, no equivalent Board could be configured on the online portal

They further argued that earlier engagements of candidates possessing Fauquania qualifications were governed by a different qualification regime and did not assist the applicants

During the proceedings, pursuant to an interim order, the applicants’ applications were accepted manually but were not entered into the online system.

The Original Applications were heard together because they raised substantially identical issues

Whether the applicants’ Fauquania qualifications, issued by the Bihar State Madrasa Education Board, were recognised as equivalent to Class X for the purpose of employment under the Central Government and GDS engagement?

Whether the respondents could deny consideration of the applicants’ candidature solely because the Bihar State Madrasa Education Board was not included in the online GDS recruitment portal?

Whether recognition of Fauquania as equivalent to Class X entitled the applicants to appointment or engagement as GDS?

The Tribunal applied Section 19 of the Administrative Tribunals Act, 1985, under which the applicants challenged the recruitment-related action

the constitutional principles of non-arbitrariness and equal opportunity in public employment under Articles 14 and 16 of the Constitution

It relied principally on the DoPT O.M. No. 42012/13/2007-Estt.(D) dated 23.02.2010, which recognised Fauquania issued by the Bihar State Madrasa Education Board as equivalent to Class X/Matriculation for employment under the Central Government

The Tribunal also considered the Postal Directorate’s instructions dated 14.01.2015 and 16.06.2017 prescribing a Class X qualification and directing that no equivalent Board be configured for GDS online engagement

The governing principle was that an administrative or technical restriction in an online portal could not, by itself, withdraw or nullify an otherwise subsisting Government recognition of an educational qualification; however, such recognition did not create an automatic right to appointment, since all other recruitment conditions remained applicable

The Tribunal found that the DoPT’s 2010 O.M. expressly recognised Fauquania as equivalent to Class X for Central Government employment and that the respondents produced no material showing that this recognition had been withdrawn, rescinded, or modified before the 2017 recruitment

Although the Postal Directorate’s 16.06.2017 instruction prohibited configuration of equivalent Boards on the online portal, that instruction concerned the technical administration of the recruitment system and did not lawfully alter the substantive educational qualification recognised by the Government

Accordingly, the non-availability of the Bihar State Madrasa Education Board in the drop-down menu could not justify rejection of the applicants’ candidature at the threshold.

At the same time, the Tribunal distinguished eligibility for consideration from entitlement to engagement: the applicants were required to satisfy all other conditions, including age, merit, vacancy, category and other applicable requirements

The impugned action was quashed to that limited extent.

The respondents were directed to reconsider each applicant’s candidature under the 18.09.2017 GDS recruitment notification and to pass a reasoned and speaking order within eight weeks of receipt or production of the certified order

The Tribunal clarified that the decision did not direct appointment or engagement and that Fauquania qualification alone did not confer any right to appointment; engagement would depend upon satisfaction of all other eligibility conditions, merit and availability of vacancies

Both Original Applications were accordingly allowed in limited terms, with no order as to costs.