Recruiting authorities cannot exclude expressly notified allied qualifications through unadvertised restrictions.

Four candidates challenged rejection of their candidatures for Assistant Professor posts during document scrutiny after qualifying in the written examinations.

Kartikeya Tiwari held an M.Tech in Biotechnology and a Ph.D. in Biosciences; the State rejected him because his postgraduate degree was awarded by a technology faculty, although Biotechnology was listed as an allied subject for Zoology.

Kashmi Sharma held an M.Sc. in Zoology and had qualified UGC-NET in Environmental Science, but was rejected because the advertisement mapped Zoology to NET in Life Sciences.

Dr. Kailash Prasad Jaiswal held an M.Sc. in Animal Biotechnology and relied on an institutional certificate equating it with Biotechnology; his degree was not expressly listed among the notified allied subjects.

Gauri Shankar held an M.A. in Music (Vocal), and was rejected because the advertisement required Music and stated that Music had no allied subjects.

The Court considered the candidates’ qualifications, the relevant advertisements and State instructions, and the parties’ submissions concerning academic equivalence and prior recruitment practice.

1. Whether an M.Tech in Biotechnology could satisfy the Zoology qualification requirements where the State had expressly listed Biotechnology as an allied subject.

2. Whether a candidate with an M.Sc. in Zoology could be rejected for holding NET in Environmental Science, which the State acknowledged as allied to Zoology.

3. Whether an M.A. in Music (Vocal) fulfilled the Music qualification requirement when the advertisement specified no allied subjects and universities awarded postgraduate degrees with branch specialisations.

4. Whether the Court could treat an M.Sc. in Animal Biotechnology as equivalent to the expressly listed allied subject of Biotechnology.

Under the UGC Regulations, 2018, as described by the Court, the relevant eligibility criteria included a Master’s degree with the prescribed marks in a concerned, relevant or allied subject and qualification in NET or an accredited SET, subject to the applicable recruitment terms.

The State’s executive instruction dated 22 December 2022, incorporated into the Zoology advertisement, identified 11 allied subjects, including Biotechnology and Environmental Science.

Articles 14 and 16 prohibit arbitrary and discriminatory treatment in public recruitment.

The Court distinguished enforcement of an equivalence or allied-subject recognition made by the State from judicial creation of academic equivalence. It relied on Zahoor Ahmad Rathor v. Sheikh Imtiyaz Ahmad, (2019) 2 SCC 404, and Dr. Rahul Patidar v. State of M.P., W.P. No. 42965/2025, for the principle that courts should not determine academic equivalence or add unlisted qualifications in place of the employer or expert authority.

It also relied on the Division Bench decision in Tileshwar Sahare v. State of Madhya Pradesh, W.P. No. 28972/2023, for the proposition that judicial review may address arbitrary exclusion of an established or State-recognised allied subject.

The principle lex non cogit ad impossibilia—the law does not compel the impossible—was applied to the Music qualification issue.

The Court held that Tiwari’s M.Tech was in the exact discipline—Biotechnology—that the State had listed as allied to Zoology; rejecting it based on the degree-awarding faculty added a restriction absent from the State’s instruction.

Sharma already held the core postgraduate qualification in Zoology, while Environmental Science was both listed as an allied subject and admitted by the State to be allied; the Court therefore found her rejection for NET in that subject arbitrary.

For Shankar, the Court found that universities awarded Music degrees with specialisations such as Vocal or Instrumental, and that the State’s prior recruitment practice and the NET/SET subject structure recognised Music as the broader discipline. It concluded that demanding an abstract, undifferentiated Music degree would impose an impossible condition.

Jaiswal’s case differed: Animal Biotechnology was not on the State’s list, and accepting the certificate as establishing equivalence would require the Court to add an unlisted qualification through its own academic assessment, which the cited authorities precluded.

It quashed the respective rejection decisions and directed the respondents to treat Tiwari’s M.Tech in Biotechnology as a valid allied qualification, Sharma as qualified on the basis of her M.Sc. in Zoology and NET in Environmental Science, and Shankar’s M.A. in Music (Vocal) as satisfying the Music academic requirement.

It dismissed W.P. No. 44910 of 2025, affirming Jaiswal’s rejection because Animal Biotechnology was unlisted and the Court would not determine its equivalence to Biotechnology.

The connected petitions were disposed of with no order as to costs.