The Supreme Court has clarified that a candidate cannot be disqualified only because their degree title differs from the specified qualification, as long as they have studied the essential subject required for the post.

A Bench of Justices Sanjay Karol and Vipul M. Pancholi restored the appointment of an M.Com (Commerce) postgraduate who was hired as a Monitoring and Evaluation Consultant—a role requiring a postgraduate qualification in Statistics—but was later terminated on the ground that his degree did not explicitly mention Statistics, despite having Business Statistics and Indian Economic Statistics as primary subjects.

Observing that the absence of a degree title should not outweigh actual academic content, the Court remarked, “Placing total emphasis on the nomenclature of a degree without evaluating the curriculum is nothing but giving precedence to form over substance. Such a narrow approach has no support in law. The phrase ‘Postgraduate degree in Statistics’ must be interpreted in a contextual, purposive manner.”

The dispute stemmed from a November 2012 recruitment notification requiring a PG degree in Statistics for the Consultant post. The appellant, whose candidature was initially accepted, joined in 2013 on a contractual basis. However, an eight-member committee later found his qualification unsuitable and issued a termination order. Although the Madhya Pradesh High Court repeatedly set aside the termination, the State continued issuing fresh orders on identical grounds, leading to an appeal before the Supreme Court.

Justice Karol pointed out that no government university in Madhya Pradesh offers a postgraduate programme formally known as “M.Com (Statistics),” making a literal requirement impractical. The Court termed such a rigid interpretation “unreasonable and arbitrary,” noting that Statistics as a major subject must be duly considered for eligibility.

It was held that judicial intervention is warranted where a contractual employee is removed solely on eligibility grounds, especially when relevant academic records are overlooked. Since the appellant had, in fact, studied substantial statistical coursework meeting the functional requirement of the post, the Court restored his appointment.

Consequently, the appeal was allowed.

Case Title: Laxmikant Sharma vs. State of Madhya Pradesh & Ors.