Courts Should Not Second-Guess Employer's Decision on Qualification Equivalence: Supreme Court Restores Appointments of Junior Engineers in Lakshadweep

Supreme Court Overturns Kerala High Court’s Ruling holds that Diploma in Electrical and Electronics Engineering is Equivalent to Diploma in Electrical Engineering. In a landmark ruling on recruitment law, the Supreme Court held that courts must not interfere in an employer’s decision regarding the equivalence of educational qualifications unless it is arbitrary or irrational. The Court set aside the Kerala High Court’s judgment and the Central Administrative Tribunal's (CAT) order, which had invalidated the selection of candidates holding a Diploma in Electrical and Electronics Engineering for the post of Junior Engineer (Electrical) in the Lakshadweep Electricity Department.

The Supreme Court emphasized that it is the prerogative of the recruiting authority to determine qualification equivalence, particularly when it is backed by expert consultation. The ruling reinstates the appointments of the selected candidates, restoring the legitimacy of recruitment processes based on administrative expertise.

"Equivalence of qualifications is primarily a matter for the employer to decide. When the recruiting authority, after due consideration and expert consultation, determines two qualifications as equivalent, courts should not interfere unless the decision is patently arbitrary or perverse," the Court observed.

Supreme Court Holds Employer’s Interpretation of Recruitment Rules is Final Unless Shown to be Arbitrary

The case arose from the recruitment process conducted by the Lakshadweep Electricity Department, which issued an advertisement for the post of Junior Engineer (Electrical). The advertised qualification required either a Degree in Electrical Engineering or a Diploma in Electrical Engineering with two years of experience.

The appellants, who held Diplomas in Electrical and Electronics Engineering, were selected for the post. However, the non-selected candidates challenged their appointment before the CAT, arguing that their qualification did not precisely match the one prescribed in the advertisement. The CAT agreed with this contention and invalidated the selection, holding that unstated qualifications cannot be read into the notification.

The selected candidates challenged this decision before the Kerala High Court, but the High Court upheld the CAT’s ruling, emphasizing that the recruitment rules did not explicitly mention a Diploma in Electrical and Electronics Engineering as an acceptable qualification.

Aggrieved by the High Court’s decision, the selected candidates approached the Supreme Court, arguing that the recruiting authority had already recognized their diploma as equivalent to a Diploma in Electrical Engineering based on expert consultation.

"Administrative Expertise Prevails Over Judicial Interpretation in Recruitment Matters"
The Supreme Court overruled the High Court and the CAT, stating that the Lakshadweep Electricity Department had sought expert clarification from the Directorate of Technical Education, Kerala, which confirmed that the two diplomas were equivalent. The Court noted: "The employer, after consulting technical experts, had accepted the Diploma in Electrical and Electronics Engineering as equivalent. The High Court erred in substituting its own judgment for that of the recruiting authority."

Referring to past precedents, the Court reiterated that courts must exercise judicial restraint in recruitment matters. Citing Anand Yadav v. State of U.P., the Supreme Court held: "The employer is the best judge of what qualifications are necessary for a post. Courts should not interfere with the employer’s discretion unless the decision is manifestly arbitrary or perverse."

The Court also relied on Mukul Kumar Tyagi v. State of U.P., stating: "Equivalence of qualifications is a matter of scrutiny by the recruiting agency. It is not for candidates or courts to determine what qualifications should be accepted—this function belongs solely to the employer."

The Supreme Court criticized the High Court for taking a hyper-technical approach in interpreting the recruitment rules. It observed: "Even if some ambiguity exists, recruitment rules must be interpreted in a practical manner, keeping in view the intent of the employer. Courts should not rigidly enforce literal interpretations at the cost of fairness and administrative efficiency."

The Court also referred to Union of India v. Uzair Imran, where it was held that the judiciary should not engage in determining the equivalence of qualifications unless there is overwhelming evidence of arbitrariness.

The Supreme Court noted that the employer had applied its mind and taken an informed decision on equivalence. Since the employer itself had no objection to the selected candidates' qualifications, the High Court’s interference was unwarranted.

Conclusion: Supreme Court Upholds Employer’s Discretion in Qualification Equivalence, Restores Appointments
The Supreme Court allowed the appeals, set aside the judgments of the Kerala High Court and CAT, and reinstated the selected candidates' appointments.

"The recruiting authority had determined that the appellants’ qualifications met the prescribed criteria. In the absence of any demonstrated arbitrariness, courts should not intervene. The High Court and CAT orders are unsustainable in law and are accordingly set aside," the Court ruled.

With this judgment, the Supreme Court has reaffirmed that courts must defer to administrative expertise in recruitment matters and should not substitute their own judgment unless there is clear illegality or irrationality.

Date of Decision: 20 February 2025