Simultaneous regular and distance degrees are valid for recruitment unless expressly prohibited by the recruitment advertisement.

The Petitioner applied for the post of Lecturer (Mathematics) pursuant to an advertisement dated 09.03.2019 issued by the School Education Department.

The prescribed qualifications were a Post-Graduate degree in Mathematics and a B.Ed. degree.

The Petitioner successfully cleared the written examination and attended document verification on 19.05.2022.

However, her candidature was rejected via an order dated 22.07.2022 on the ground that she obtained two degrees (B.Ed. in regular mode and M.Sc. in distance mode) during the same academic session.

The Petitioner completed her B.Ed. (regular) from Pt. Ravishankar Shukla University in 2017 and her M.Sc. (distance) from Pt. Sundarlal Sharma University with the final result declared in 2018.

The State defended the rejection by citing Ordinance 6 of the Chhattisgarh Universities Act, 1973, which prohibits appearing in more than one degree examination in the same year.

1. Whether the rejection of the petitioner’s candidature on the ground of possessing simultaneous degrees is legally sustainable when such a disqualification was not stipulated in the recruitment advertisement.

2. Whether the University Grants Commission (UGC) guidelines permitting the pursuit of two academic programmes simultaneously override internal university ordinances in the context of public recruitment.

The court primarily relied on the "rules of the game" doctrine established in Tej Prakash Pathak v. High Court of Rajasthan (2025) 2 SCC 1, which mandates that eligibility criteria cannot be altered after the recruitment process has commenced.

It further applied the University Grants Commission (UGC) “Guidelines for Pursuing Two Academic Programmes Simultaneously” (2012 and 2022), which expressly permit a student to pursue one regular degree alongside one degree in distance or online mode.

The court also invoked the principles of fairness and equality in public employment under Articles 14 and 16 of the Constitution of India.

The court reasoned that the recruitment advertisement dated 09.03.2019 contained no express prohibition against candidates holding degrees obtained simultaneously in regular and distance modes.

By introducing this disqualification during the document verification stage, the Respondents impermissibly altered the eligibility criteria post hoc, violating the settled principle that the "rules of the game" cannot be changed midway.

Furthermore, the court found that the Petitioner’s academic path—combining a regular B.Ed. with a distance-mode M.Sc.—was strictly in accordance with UGC norms.

The Respondents' reliance on Ordinance 6 of the Chhattisgarh Universities Act, 1973, was deemed insufficient to override the specific terms of the recruitment advertisement and the overarching regulatory framework provided by the UGC.

Consequently, the rejection was characterized as arbitrary and a denial of legitimate opportunity.

It held that the Petitioner was wrongly disqualified on grounds neither reflected in the advertisement nor consistent with UGC norms.

The Respondents were directed to reconsider the Petitioner’s candidature for appointment to the post of Lecturer afresh, strictly according to the original advertisement and UGC guidelines, without imposing new disqualifications.

The process must be completed within sixty days of receipt of the judgment.