Recruiting authorities must assess a qualification’s substantive curriculum, not merely its nomenclature, for eligibility.

The applicant challenged, under Section 19 of the Administrative Tribunals Act, 1985, the respondents’ order dated 30 July 2021 cancelling her candidature for the post of Assistant Loco Pilot under CEN No. 01/2018 on the ground that her Five-Year Integrated M.Tech. in Energy Engineering did not satisfy the prescribed qualification.

The recruitment notification required a three-year Diploma in Mechanical, Electrical, Electronics or Automobile Engineering, or a combination of those streams; a degree in the same engineering disciplines was also acceptable in lieu of the diploma.

The applicant had obtained her qualification from the Central University of Jharkhand in 2016 and successfully cleared the First Stage CBT, Second Stage CBT and Computer-Based Aptitude Test.

She was provisionally shortlisted for document verification and secured 72.242 marks, compared with 72.05 marks obtained by the last selected General Category candidate.

During document verification, she produced a certificate dated 15 July 2019 from the Head of the Department of Energy Engineering certifying that Energy Engineering was considered a combination of Electrical and Mechanical Engineering with respect to course structure and credit points.

She also relied on relevant AICTE materials, including the Gazette Notification dated 28 April 2017, which stated that Energy Engineering “may be from Electrical or Mechanical Engineering”.

Whether the applicant’s Five-Year Integrated M.Tech. in Energy Engineering satisfied the educational qualification prescribed for Assistant Loco Pilot under CEN No. 01/2018.

Whether the respondents acted lawfully in cancelling the applicant’s candidature solely because the nomenclature of her degree was “Energy Engineering,” without adequately considering its curriculum, course structure and the University’s equivalence certificate.

Whether the applicant was entitled to consideration for appointment, subject to fulfilment of the remaining eligibility conditions and her merit position.

The Tribunal applied Section 19 of the Administrative Tribunals Act, 1985, governing the applicant’s challenge to the recruitment decision.

It interpreted the educational qualification under CEN No. 01/2018, which prescribed a diploma in Mechanical, Electrical, Electronics or Automobile Engineering, or a combination of those disciplines, while permitting a degree in the same disciplines in lieu of the diploma.

The Tribunal relied on the principle in Sajid Khan v. L. Rahmathullah & Others, 2025 INSC 251, that equivalence should not be determined through an unduly technical approach where there is no substantial difference between qualifications and that the substantive academic content must be considered.

It also relied on Laxmikant Sharma v. State of Madhya Pradesh & Others, 2025 SCC OnLine SC 2712, which held that insisting solely on the title of a degree, without examining its actual curriculum, elevates form over substance; however, the determination of equivalence ordinarily remains within the domain of the employer or competent expert body.

The AICTE Gazette Notification dated 28 April 2017, indicating that Energy Engineering may derive from Electrical or Mechanical Engineering, was also treated as relevant supporting material.

The Tribunal found that the applicant’s claim was supported not merely by her own assertion of equivalence but by a certificate issued by the academic authority of the Central University of Jharkhand, specifically linking Energy Engineering with Electrical and Mechanical Engineering on the basis of course structure and credit points.

The AICTE Gazette material independently supported the possibility of Energy Engineering being based on Electrical or Mechanical Engineering.

Although the Tribunal recognised that it should not ordinarily substitute its view for that of the recruiting authority on academic equivalence, it held that the respondents had not produced cogent material demonstrating that the applicant’s curriculum was substantially different from the prescribed engineering disciplines.

Since the respondents had proceeded primarily on the nomenclature of the degree and had failed to examine its substantive academic content, the cancellation was held to be inconsistent with the form-over-substance principle laid down in Sajid Khan and Laxmikant Sharma.

The applicant’s successful completion of the selection stages and her merit position further supported reconsideration, although appointment remained subject to all other eligibility requirements and her final merit position.

The Tribunal quashed and set aside the order dated 30 July 2021 cancelling the applicant’s candidature.

The competent authority was directed to process her candidature for the post of Assistant Loco Pilot by treating her as educationally eligible under CEN No. 01/2018, subject to fulfilment of all other eligibility conditions and her merit position.

If she was otherwise entitled on the basis of the selection results, consequential action was to be taken in accordance with law within three months of receipt of the certified order.

No order as to costs was made.

Pending miscellaneous applications, if any, were disposed of.