In a significant ruling, the Allahabad High Court emphasized that employers alone hold the authority to determine equivalence of qualifications for job eligibility, barring courts from intervening in such matters. The bench of Justices Attau Rahman Masoodi and Subhash Vidyarthi dismissed a special appeal filed by Saurabh Saxena, who contested the rejection of his application for an Instructor post due to non-equivalent qualifications.
Case Background: Dispute Over Qualification Equivalence
The Uttar Pradesh Subordinate Services Selection Commission (UPSSSC) advertised vacancies for Instructors in Sewing Technology, mandating specific diplomas or certifications. The appellant, Saurabh Saxena, held a 3-year Diploma in Textile Technology and a National Craft Instructor Certificate in “Cutting & Sewing” but lacked the prescribed credentials:
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Diploma in Garment Fabrication Technology/Costume Design & Dress Making, NTC/NAC certification in Sewing Technology.
His candidature was rejected as his qualifications did not match Column 4 of the Uttar Pradesh Government Industrial Training Institutes Service Rules, 2021. Saxena argued his diploma was equivalent to Costume Design & Dress Making under the “Textile Engineering” discipline, citing a document from the U.P. Technical Education Board. However, the Writ Court and later the Review Court dismissed his claims, stating equivalence must be explicitly declared by the employer, not inferred.
Courts Uphold Employer’s Prerogative
The High Court relied on Supreme Court judgments to underscore its decision:
District Collector vs. M. Tripura Sundari Devi (1990):
The Supreme Court ruled that appointing candidates lacking advertised qualifications amounts to “fraud on the public.” Relaxations are permissible only if explicitly stated, ensuring fairness to other eligible candidates who might have refrained from applying.
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Zahoor Ahmad Rather vs. Sheikh Imtiyaz Ahmad (2019):
The Apex Court clarified that prescribing qualifications is a policy matter for the employer. Courts cannot expand eligibility criteria or adjudicate equivalence, as such decisions involve administrative and technical assessments.
Reiterating the above, the Supreme Court stressed that equivalence requires explicit recognition by academic bodies or employers, not assumptions
Why Saxena’s Appeal Failed The High Court noted critical gaps in Saxena’s case:
While the advertisement permitted equivalence for High School exams, it omitted such provisions for diplomas.
The Secretary of the U.P. Technical Education Board merely suggested possible equivalence but did not formally declare it.
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Citing precedents, the bench emphasized courts lack expertise to equate qualifications, as this could disadvantage other candidates who adhered to the rules.
“If equivalence is allowed judicially, similarly situated candidates who did not apply due to rigid criteria would suffer injustice,” the Court remarked.
Upholding Fair Recruitment Practices
The ruling reinforces that employers retain exclusive rights to set and interpret eligibility criteria, ensuring transparency and fairness in recruitment. By dismissing the appeal, the High Court upheld the Writ Court’s decision, safeguarding the integrity of public employment processes.
Case Title: Saurabh Saxena v. Union of India & Others [SPECIAL APPEAL DEFECTIVE No. 10 of 2025]
