TGT hopeful who missed bachelor’s cutoff can’t use one-year IGNOU course without proof of equivalence, P&H HC rules

In brief

The question

1. Whether the petitioner’s one-year Associate Course in English Literature from IGNOU could be treated as equivalent to the Bachelor’s Degree required by the recruitment advertisement, thereby making him eligible for the post of TGT English.

The court held

The Court held that the petitioner had not established that he possessed the essential educational qualification prescribed by the advertisement and found no ground to interfere with the respondents’ decision.

It also directed

The writ petition was dismissed, and any pending miscellaneous applications were disposed of.

01Facts

The petitioner applied for the post of TGT English (ROH) under the BCB category pursuant to an advertisement dated 21 February 2023.

pp. 1–3, 5

The advertisement required a Bachelor’s Degree with at least 50% marks in English, subject to a 5% relaxation for eligible reserved-category candidates.

pp. 1–3, 5

The petitioner’s Bachelor’s Degree from Maharshi Dayanand University did not meet the applicable qualifying threshold, even after an improvement examination.

pp. 1–3, 5

He relied instead on a one-year Associate Course in English Literature from IGNOU, passed in 2018, and contended that it should be considered equivalent to the required Bachelor’s Degree.

pp. 1–3, 5

The respondents rejected his candidature, and he sought to quash the result and obtain consideration for appointment.

pp. 1–3, 5

02Issues

i.1. Whether the petitioner’s one-year Associate Course in English Literature from IGNOU could be treated as equivalent to the Bachelor’s Degree required by the recruitment advertisement, thereby making him eligible for the post of TGT English.

pp. 5–6

ii.2. Whether the Court could interfere under Article 226/227 with the respondents’ decision to reject the petitioner’s candidature for failure to meet the prescribed educational qualification.

pp. 6–8, 12

03Law Applied

Under Article 226/227, courts ordinarily do not interfere with clear eligibility criteria prescribed by a recruiting authority, absent illegality, arbitrariness, or inconsistency with statutory rules.

pp. 6–8

The employer determines the qualifications relevant to a post, and courts cannot rewrite an advertisement or determine academic equivalence in place of the employer or competent academic authorities (*Maharashtra Public Service Commission v. Sandeep Shriram Warade*, (2019) 6 SCC 362; *M.D. Firoz Mansuri v. State of Bihar*, 2026 INSC 68).

pp. 6–8

The Court also relied on *Nipun Syal v. State of Punjab*, CWP-14254-2022 (O), decided 26 August 2025, and the principles in *Ganpath Singh Gangaram Singh Rajput v. Gulbarga University*, (2014) 3 SCC 676, and *Devender Bhaskar v. State of Haryana*, 2022 (1) SCT 51, concerning the limits of judicial review over prescribed qualifications and equivalence.

pp. 8–12

The advertisement allowed a 5% relaxation in qualifying marks for specified reserved categories, but that relaxation did not remove the requirement to possess the prescribed Bachelor’s Degree.

pp. 4–5, 12–13

04Reasoning

The petitioner had not obtained the required qualifying marks in his Bachelor’s Degree, including after attempting to improve them.

pp. 9–11

His IGNOU course was a one-year Associate Course, whereas the advertisement prescribed a Bachelor’s Degree.

pp. 9–11

The record contained no material showing that the Associate Course had been recognised by a competent authority as equivalent to the required degree for this recruitment.

pp. 9–11

Its subject matter, marks, timely completion, or submission with the application could not cure the deficiency in the prescribed qualification.

pp. 9–11

In light of the limits on judicial review of academic equivalence, the Court declined to substitute the Associate Course for the qualification specified by the recruiting authority.

pp. 9–11