Possession of essential degree on cutoff date is mandatory; completion of internship post-deadline disqualifies candidature.

The petitioner applied for the post of Physiotherapist pursuant to an advertisement dated February 3, 2016

The eligibility criteria required candidates to possess a valid degree in physiotherapy from a recognized university as of the cutoff date, February 18, 2016

Although the petitioner cleared the selection rounds, document verification revealed she held only a provisional degree

Records showed she completed her mandatory six-month internship on March 31, 2016—over a month after the cutoff date

Consequently, respondent No. 3 excluded her from the select list published on August 11, 2016. The petitioner filed this writ petition on August 1, 2018, seeking appointment and challenging her exclusion

1. Whether the petitioner fulfilled the eligibility criteria of possessing a valid degree as of the cutoff date prescribed in the advertisement

2. Whether the writ petition is maintainable despite being filed nearly two years after the publication of the select list

The court applied Articles 14, 16, and 226 of the Constitution of India regarding equality in public employment

University Regulations (O.B. Physio-9) of Saurashtra University, which mandate that a Bachelor of Physiotherapy degree is only qualified for after the successful completion of a six-month compulsory rotating internship

State of Orissa v. Rajkishore Nanda, which holds that a select list is not a permanent reservoir and no relief can be granted to a candidate who approaches the court after the list has expired

Girdhar Kumar Dadhich v. State of Rajasthan, affirming that the life of a select list is typically one year, after which it lapses

The court reasoned that since the university regulations clearly state that the degree is only conferred after the internship, the petitioner did not possess a valid degree on the cutoff date of February 18, 2016, as her internship ended on March 31, 2016

Therefore, the respondent's decision to exclude her was not arbitrary but was in strict adherence to the advertised eligibility norms

Furthermore, the court addressed the issue of delay; the select list was published in August 2016, but the petitioner approached the High Court in August 2018. Following the precedents of the Supreme Court, the court found that the life of the select list (typically one year) had already expired, rendering the petitioner's claim belated and legally unsustainable

The court held that no fault could be found with the respondent's decision to exclude a candidate who did not possess the requisite qualification at the time of application

The petition was dismissed, and the Rule was discharged with no order as to costs