Tribunals cannot substitute their assessment for competent authorities’ determination of academic qualification equivalence.

The applicant possessed a B.Tech. in Agricultural Engineering from SKUAST, an M.Tech. in Hydrology from IIT Roorkee, and had qualified the NET in Land and Water Management Engineering

Pursuant to Advertisement Notification No. 10-PSC (DR-P) of 2017 dated 27.10.2017, he applied under the RBA category for the post of Assistant Professor, Water Management, in the Higher Education Department

During scrutiny, his eligibility was kept subject to clarification because his M.Tech. was in Hydrology/Surface Water rather than Water Management

An Equivalence Committee constituted by the General Administration Department examined the equivalence of various degrees.

Its decision, communicated by the Higher Education Department on 13.10.2020, treated an M.Tech. in Hydrology/Surface Water as not equivalent to the prescribed Master’s degree in Water Management

The JKPSC consequently rejected the applicant’s candidature through the shortlisting/rejection notice dated 03.08.2021, despite his representation and supporting material

The applicant challenged the rejection notice, the interview notice dated 27.08.2021, the constitution of the Equivalence Committee, and sought reconsideration of equivalence by subject experts under Section 19 of the Administrative Tribunals Act, 1985

Whether the applicant’s M.Tech. degree in Hydrology/Surface Water from IIT Roorkee was equivalent to the prescribed Master’s degree in Water Management for appointment as Assistant Professor?

Whether the Tribunal could interfere with the determination of academic equivalence made by the competent Equivalence Committee and substitute its own assessment based on syllabus overlap and expert material relied upon by the applicant?

Whether the constitution or functioning of the Equivalence Committee was so defective, arbitrary, or unlawful as to invalidate its decision and require fresh consideration by specialised experts?

The Tribunal applied Section 19 of the Administrative Tribunals Act, 1985, under which the applicant challenged the service-related recruitment decision

It applied the applicable Education (Gazetted) College Service Recruitment Rules, 2008, as amended, which required the prescribed academic qualification in the relevant subject, together with the applicable NET/SET/SLET requirement

The Tribunal held that prescription of educational qualifications and determination of equivalence primarily fall within the domain of the competent academic or administrative authorities; a recruiting body and court or tribunal should not enlarge the eligibility criteria by treating another qualification as equivalent merely because of similarity or overlap in course contents

Judicial interference was therefore unwarranted absent mala fides, patent arbitrariness, or illegality in the competent authority’s determination

The applicant’s M.Tech. in Hydrology and his claim that several subjects overlapped with Water Management did not establish legal equivalence with the qualification expressly prescribed in the recruitment process

The competent Equivalence Committee had specifically examined the relevant qualifications and concluded that M.Tech. in Hydrology/Surface Water was not equivalent to a Master’s degree in Water Management

Since the JKPSC merely acted upon that determination, its rejection of the candidature was not an independent or arbitrary decision

The Tribunal declined to reassess the academic content of the degrees or substitute its own view for that of the competent authority.

The applicant also failed to demonstrate mala fides, manifest arbitrariness, or any legal defect in the Committee’s constitution sufficient to invalidate its decision

It found no illegality or arbitrariness in the Equivalence Committee’s determination or in the JKPSC’s rejection of his candidature

The Original Application was accordingly dismissed, and any pending miscellaneous applications were also disposed of, with no order as to costs