Recruiting authorities may strictly enforce notified qualifications; courts cannot expand them through judicially determined equivalence.

The Railway Recruitment Board issued Centralised Employment Notice No. 01/2024 for recruitment to the post of Assistant Loco Pilot. The prescribed qualifications included Matriculation/SSLC with specified ITI or apprenticeship qualifications, or a three-year Diploma/Degree in Mechanical, Electrical, Electronics, Automobile Engineering, or a combination of those streams.

The applicant, who held a B.Tech. degree in Production Engineering with a minor in Chemical Engineering, applied for the post and, in the online application, declared Mechanical Engineering as his qualification.

He was provisionally permitted to participate in the CBT-I, CBT-II and Computer-Based Aptitude Test, cleared them, and was called for document verification.

During document verification, the Railway Recruitment Board found that his degree was in Production Engineering rather than Mechanical Engineering and rejected his candidature as not satisfying the notified qualification.

Whether a candidate possessing a B.Tech. degree in Production Engineering satisfies the notified educational qualification of a Degree/Diploma in Mechanical Engineering for appointment as Assistant Loco Pilot.

Whether the Tribunal could treat Production Engineering as equivalent to Mechanical Engineering on the basis of the AICTE Approval Process Handbooks, the university Dean’s certificate and overlapping curriculum, despite the absence of express recognition by the Railway Recruitment Board.

Whether the applicant’s participation in and success at the computer-based tests created any enforceable right to further consideration or appointment despite failure to satisfy the essential qualification at document verification.

The Tribunal applied the eligibility conditions in CEN No. 01/2024, under which candidature remained provisional until verification of educational qualifications and could be cancelled if the prescribed criteria were not satisfied.

It relied principally on Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad, (2019) 2 SCC 404, holding that prescription of qualifications is a matter of recruitment policy and that judicial review cannot expand the scope of prescribed qualifications or determine equivalence.

The same principle was reiterated from Shifana P.S. v. State of Kerala, (2024) 8 SCC 309, and Mukul Kumar Tyagi v. State of Uttar Pradesh, (2020) 4 SCC 86, which place the determination of equivalence and scrutiny of qualifications with the recruiting agency.

Relying on Basic Education Board, U.P. v. Upendra Rai, (2008) 3 SCC 432, the Tribunal held that equivalence is an administrative and expert determination warranting judicial restraint.

It also referred to Guru Nanak Dev University v. Sanjay Kumar Katwal, (2009) 1 SCC 610, for the proposition that academic equivalence must be established through a specific, duly published decision of the competent academic body.

The AICTE Approval Process Handbooks were treated as instruments of academic and regulatory classification, not as rules conferring equivalence for railway recruitment.

The Tribunal held that the recruitment notification specifically identified Mechanical, Electrical, Electronics and Automobile Engineering and did not include Production Engineering.

The applicant’s reliance on the AICTE Handbooks and the Dean’s certificate could not alter that position because those materials classified courses for academic and regulatory purposes but did not establish equivalence for employment under the Railway Recruitment Rules.

The Tribunal further found that the university certificate was not a formal resolution or published decision declaring Production Engineering equivalent to Mechanical Engineering, and that curriculum overlap or eligibility for admission to related postgraduate courses was insufficient to prove recruitment equivalence.

Since the Railways had consciously prescribed technical qualifications connected with the safety and operational requirements of the Assistant Loco Pilot post, the Tribunal declined to substitute its own assessment of the suitability or comparative value of Production Engineering.

The applicant’s success in the tests did not cure the basic eligibility defect because participation was expressly provisional and subject to document verification.

The Tribunal also noted that the applicant had declared Mechanical Engineering in the application despite holding a Production Engineering degree, although it did not base the dismissal solely on that misstatement.

It held that the Railway Recruitment Board was entitled to reject the candidature at document verification and that the Tribunal could not judicially expand the prescribed qualifications or determine equivalence.

The Original Application was accordingly dismissed, with no order as to costs.