Sastri Degree Is Equivalent To B.A. : Orissa High Court Upholds Appointment Of Hindi Teacher, Dismisses State’s Appeal

“Rastrabhasa Sastri is to be treated at par with +3/B.A. — Marks obtained therein must be reckoned for eligibility” – In a landmark pronouncement deepening the jurisprudence on educational equivalence in public recruitment, the Orissa High Court dismissed the State Government’s appeal in State of Odisha v. Pabitra Behera, thereby affirming that a “Rastrabhasa Sastri” qualification obtained from Odisha Rastrabhasa Parisad, Puri, is equivalent to a Bachelor’s Degree (+3/B.A.) for the purpose of recruitment of contractual Hindi teachers.

Delivering judgment in Writ Appeal No. 723 of 2025, a Division Bench comprising Chief Justice Harish Tandon and Justice Murahari Sri Raman upheld the Single Judge’s decision that had directed the State to appoint the respondent, Pabitra Behera, as a Contractual Hindi Teacher under the School & Mass Education Department’s Resolution dated 27.10.2014.

The Bench emphatically held:

“When the Utkal University and the Government of India have already recognised ‘Rastrabhasa Sastri’ as equivalent to +3/B.A., the marks secured in that examination cannot be ignored in determining eligibility for appointment.”

“Equivalence Declared by Competent Authorities Cannot Be Rejected by Executive Authorities”

The controversy arose after the Collector, Angul rejected Behera’s candidature on the ground that he had secured less than 45% marks in his B.A. degree, ignoring his 63.75% marks in the Rastrabhasa Sastri examination.

The Single Judge had earlier set aside this decision and directed Behera’s appointment. The State appealed, contending that Sastri could not be treated as equivalent to a degree unless specifically declared so by the Odisha Government.

Rejecting the State’s plea, the Division Bench referred to official communications and precedents establishing such equivalence, including the Utkal University Notification dated 28.10.2011, which explicitly recognized:

“Rastrabhasa Sastri from Odisha Rastrabhasa Parisad, Puri, shall be treated as equivalent to +3 Hindi Pass (B.A.).”

The Court also cited the Government of India, Ministry of Education’s Letter dated 26.07.1979, which had recognised the Sastri examination as equivalent to a B.A. standard, alongside similar recognitions for “Praveen” (Intermediate) and “Vinod” (SLC).

“Clause 3(f) of the 2014 Resolution Must Be Read Disjunctively, Not Conjunctively”

A central question before the Bench was the interpretation of Clause 3(f) of the 2014 Recruitment Resolution, which prescribes the educational qualifications for Hindi Teachers. The State argued that a candidate must possess both a Bachelor’s degree and a Sastri qualification.

Rejecting that reading, the Court invoked the golden principles of statutory construction and ruled that the qualifications are alternative and disjunctive, not cumulative.

Justice Murahari Sri Raman, authoring the judgment, observed:

“Clause 3(f) uses ‘or’ to prescribe alternative qualifications—‘Bachelor’s degree with Hindi as one of the elective subjects’ or ‘Rastrabhasa Sastri’ from Odisha Rastrabhasa Parisad, Puri.’ Both need not co-exist. To construe otherwise would defeat the object of the Resolution and result in absurdity.”

Referring to CIT v. Puthu Thotam Estates (1981) 127 ITR 481 (Mad) and Central Council for Research in Ayurvedic Sciences v. Bikartan Das (2023) 11 SCR 731, the Court reiterated that the words “and” and “or” may be read interchangeably only to avoid absurd or unintended consequences.

“Untrained Candidates Can Apply; Training Can Follow Appointment”

The Division Bench also reaffirmed the established position that untrained candidates are not barred from applying for the post of Contractual Hindi Teacher. The 2014 Resolution expressly allows untrained candidates to undergo training “within the timeline prescribed by the Government.”

Citing its own earlier decisions in Nihar Ranjan Sarangi v. State of Odisha (2021) and Satyabrata Nayak v. State of Odisha (2021), the Court noted:

“An untrained candidate who otherwise possesses the required educational qualification cannot be denied appointment merely because training was not completed at the time of application. The training condition is subsequent and curable.”

This principle, the Court emphasized, was crucial to ensuring that large vacancies in government schools do not persist due to rigid interpretation of qualification norms.

“Judicial Consistency Must Be Maintained; State’s Appeal Devoid of Merit”

The Bench noted that the State had repeatedly failed in similar matters, including Smruti Rekha Mishra v. State of Odisha (2022 (I) ILR-CUT 219) and State of Odisha v. Aparna Sinha (W.P.(C) No.10616/2020), both of which upheld “Sastri” as equivalent to B.A.

Significantly, the Supreme Court had dismissed the State’s SLP in Aparna Sinha’s case on 20 January 2021, lending finality to that interpretation.

In a strongly worded passage, the Court remarked:

“The State has failed to demonstrate any distinguishing fact or perversity in the findings of the learned Single Judge. The consistent judicial view treating ‘Sastri’ as equivalent to +3/B.A. cannot be unsettled merely because the State remains unwilling to accept it.”

“Sastri Marks Must Be Counted; Rejection by Collector Unsustainable”

Concluding that Behera had secured 63.75% marks in Sastri, which far exceeded the minimum 45% requirement for Scheduled Caste candidates, the Court held that his eligibility stood clearly established.

The Division Bench thus affirmed the Single Judge’s directive:

“The Collector, Angul, committed manifest error in not reckoning the Sastri marks while computing aggregate percentage. The rejection order dated 20.01.2023 cannot be sustained.”

Appeal Dismissed, Appointment Upheld

The Division Bench dismissed the appeal filed by the State of Odisha, upholding the Single Judge’s order dated 28 November 2024, and sustained the direction to appoint Pabitra Behera as Contractual Hindi Teacher in Government High School, Angul District.

In its concluding paragraph, the Bench observed:

“In the wake of the authoritative recognition of ‘Sastri’ as equivalent to +3/B.A., and the respondent having secured more than 45% marks therein, the reasons cited for rejection are unsustainable. The appeal, devoid of merit, stands dismissed. No order as to costs.”

“Recognition once granted cannot be disowned — administrative authorities are bound by declared equivalence”

The ruling consolidates a consistent judicial stance across multiple Benches that the “Rastrabhasa Sastri” degree holds parity with a regular Bachelor’s degree, ensuring that thousands of similarly qualified Hindi scholars in Odisha are not arbitrarily excluded from government teaching posts.

Date of Decision: 14 October 2025