The appellant was appointed as Monitoring & Evaluation Consultant in the Water Support Organisation of the P.H.E.D., Bhopal in 2013, based on an advertisement requiring a “Postgraduate degree in Statistics” with minimum 60% marks. He possessed an M.Com. degree, in which Business Statistics and Indian Economic Statistics were principal subjects. After nearly a year of satisfactory service, an 8-member committee concluded that he lacked the prescribed qualification and his contractual services were terminated.
In multiple litigation rounds, the High Court set aside the earlier termination orders and directed reconsideration after giving fair opportunity. However, the State repeatedly re-terminated him, insisting that M.Com. (with statistical subjects) is not equivalent to a PG degree titled “Statistics.”
The Supreme Court noted key facts:
✔ No Government university in Madhya Pradesh offers a PG degree specifically titled “Statistics.”
✔ The College/University certified that the appellant’s M.Com. included principal statistical subjects.
✔ The Director, W.S.O., S.W.M., P.H.E.D. issued a reasoned expert opinion affirming the appellant’s eligibility and recommending his continuation.
✔ Other similarly qualified candidates were retained, without rational distinction.
✔ The inquiry committee acted without hearing him, violating natural justice.
The Court held that the authorities acted arbitrarily by:
• Elevating form over substance — insisting only on nomenclature of degree
• Ignoring relevant evidence supporting eligibility
• Repeatedly relying on a flawed and outdated committee report
• Violating fairness and equal protection under Article 14 even in a contractual setting
Judicial review was justified because the sole ground of termination — ineligibility — was factually incorrect.
Outcome
The Supreme Court:
- Set aside the High Court’s judgment affirming termination
- Declared that the appellant possessed the requisite qualification
- Directed reinstatement within four weeks with all consequential benefits
- Clarified the decision is based on peculiar facts and not to be treated as preceden