Matters of Education I

It is trite to say, often, a proposition of law as laid down in a case is as good as the facts of the case.

We say so in view of the fact, matters of education must be left to educationists, of course subject to being governed by relevant statutes and regulations. It is not the function of this Court to sit as an expert body over decision of experts, especially when the experts are all eminent people. This aspect has received judicial imprimatur even earlier and we are not saying something new. We may refer to Zahoor Ahmad Rather, (2019) 2 SCC 404 in this behalf: (a) it is for the employer to consider what functionality of qualification and content of course of studies would lead to acquisition of an eligible qualification; and (b) such matters must be left to educationists.

Hon’ble Justice Sanjay Kishan Kaul, Anand Yadav v. State of Uttar Pradesh, [Civil Appeal No. 2850 of 2020].

The Educationist

Pramod Kumar Srivastava v. Chairman, Bihar Public Service Commission, Patna, (2004) 6 SCC 714 observed, in absence of any provision for re-evaluation, examinees have no right to claim or demand re-evaluation. As observed in Ran Vijay Singh v. State of U.P., (2018) 2 SCC 357 sympathy or compassion does not play any role. Vikesh Kumar Gupta v. State of Rajasthan, (2021) 2 SCC 309 observed, academic matters are best left to academics.

Hon’ble Justice M.R. Shah, Dr. NTR University of Health Sciences v. Dr. Yerra Trinadh, [Civil Appeal No. 8037 of 2022] decided on 04.11.2022.

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Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad, (2019) 2 SCC 404 held, judicial review can neither expand ambit of prescribed qualifications nor decide equivalence of prescribed qualifications with any other qualification. Whether a particular qualification should or should not be regarded as equivalent is a matter for State, as one recruiting, to determine. Also in light of observations in Unnikrishnan CV v. Union of India, 2023 SCC OnLine SC 343 we find no justifiable reason to interfere.

Hon’ble Justice Sandeep Mehta, Shifana P.S. v. State of Kerala, [Civil Appeal No. 4468 of 2013] decided on 06.08.2024.

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The employer is best suited to decide requirements a candidate must possess; in no case can Court, in garb of judicial review, decide what is best for an employer and interpret conditions of an advertisement contrary to plain language of same [Maharashtra Public Service Commission v. Sandeep Shriram Warade, (2019) 6 SCC 362]. Though there a number of decisions on this very principle [Mohammad Shujat v. Union of India, (1975) 3 SCC 76; Dr. B.L. Asawa v. State of Rajasthan, 1982 (2) SCC 55; Zahoor Ahmad Rather v. Sheikh Imtiyaz Ahmad, (2019) 2 SCC 404] we will conclude with Union of India v Uzair Imran, 2023 SCC OnLine SC 1308 emphasizing, restraint a Court must exercise while determining equivalence between qualifications.

Hon’ble Justice Pamidighantam Sri Narasimha, Sajid Khan v. L. Rahmathullah, [Civil Appeal No. 17308 of 2017] decided on 20.02.2025.

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But, cases of hardship are likely to arise in working of almost any rule which may be framed for selecting a limited number of candidates for admission out of a long list. This, however, would not render the rule unconstitutional. 

The argument was raised in Kumari N. Vasundara v. State of Mysore (1971) 2 SCC 22, candidates whose parents, out of necessity or by compelling reasons of transfers, while remaining out of Mysore State, cannot afford to arrange for residence of their children inside Mysore State. The argument was repelled by this Court. The exclusive domain for policy formulation was not liable to be interfered with, unless validly challenged on gross discrimination, clear arbitrariness, patent illegality, perversity or unconstitutionality.

Hon’ble Justice K. Vinod Chandran, State of Telengana v. Kalluri Naga Narasimha, [Special Leave Petition (Civil) Nos. 21536-21588 of 2024] decided on 01.09.2025.