Supreme Court Says Candidate Can’t Be From Job Rejected Just for Degree Name

The Supreme Court in Laxmikant Sharma v. State of Madhya Pradesh & Ors. has held that a candidate cannot be disqualified from a job only because the title of their degree is different, as long as they have actually studied the main subject required for the post.

A Bench of Justices Sanjay Karol and Vipul M Pancholi restored the appointment of a Monitoring and Evaluation Consultant whose services were earlier terminated. The post required a postgraduate degree in Statistics. The candidate, however, held an M.Com degree but had studied Business Statistics and Indian Economic Statistics as major subjects. Despite this, his appointment was cancelled on the ground that he did not hold a formal PG degree specifically titled “Statistics.”

The Court said that focusing only on the degree title and ignoring the candidate’s actual curriculum would be “form over substance.” It added that the expression “postgraduate degree in Statistics” must be interpreted in a practical and purposive manner, especially when the candidate has studied Statistics as a principal subject.

The dispute began with a 2012 advertisement requiring a PG degree in Statistics. The candidate was hired in 2013 on contract. A year later, an inquiry committee removed him, saying that an M.Com degree did not fulfil the eligibility criteria. The Madhya Pradesh High Court repeatedly set aside the termination, but the State issued fresh termination orders on the same ground. The candidate then approached the Supreme Court.

The Court noted that no government university in Madhya Pradesh offers an M.Com (Statistics) degree. Therefore, insisting on such a qualification creates an unrealistic and “impossible” standard. It ruled that degrees where Statistics is a main subject should be treated as fulfilling the eligibility requirement.

Since the termination was based only on an incorrect interpretation of eligibility, the Supreme Court held that the candidate must be reinstated. The appeal was allowed.