Supreme Court: Candidate Cannot Be Rejected Solely for Degree Title if Core Subject Was Studied
Summary: The Supreme Court has ruled that a candidate cannot be disqualified merely because the nomenclature of their degree does not precisely match the qualification asked in a recruitment advertisement — where the requisite principal subject was in fact studied as part of the candidate’s curriculum.
Case background
The petitioner, Laxmikant Sharma, had been appointed earlier as a Monitoring & Evaluation Consultant on a contractual basis. The recruitment advertisement required a "postgraduate degree in Statistics (minimum 60%)." The petitioner possessed an M.Com. degree, and his academic records and a university certificate showed that he had studied Business Statistics and Indian Economic Statistics as principal subjects. Nonetheless, the appointing authority and subsequent High Court rejected his candidature on the ground that his degree title did not read "M.Sc. (Statistics)".
Key issues before the Court
- Whether insistence on an exact degree title (nomenclature) is reasonable when the required subject is actually part of the candidate’s curriculum.
- Whether the appointing authority’s and High Court’s reliance on the degree title — without examining curriculum evidence and departmental opinion — was arbitrary.
Supreme Court’s holding (Essentials)
The Bench (Justice Sanjay Karol & Justice Vipul M. Pancholi) held that eligibility must be judged by the substance of the candidate’s qualification — i.e., whether the required principal subject was studied — and not rigidly by degree nomenclature. The Court noted that no government university in the State offered a PG degree titled exactly "M.Sc. (Statistics)" at the relevant time, and that to insist on that title would be arbitrary and elevate form over substance. As a result, the Court set aside the termination and directed reinstatement with consequential benefits. :contentReference[oaicite:4]{index=4}
Verdict data
| Field | Details |
|---|---|
| Case title | Laxmikant Sharma v. State of Madhya Pradesh & Ors. |
| Reported citation | 2025 LiveLaw (SC) 1174 (also reported as INSC 1385 in various portals) |
| Date of judgment | 6 December 2025 (reporting portals show dates around 04–08 Dec 2025 depending on item/resource) |
| Bench | Justice Sanjay Karol & Justice Vipul M. Pancholi |
| Relief granted | Set aside termination; reinstatement as Monitoring & Evaluation Consultant with consequential benefits |
| Key legal principle | Substance (curriculum/subjects studied) prevails over mere degree nomenclature for recruitment eligibility |
| Official/Full judgment (PDF) | Full judgment PDF (Verdictum copy) |
| Supreme Court record (ROPs / item) | Supreme Court - Record of Proceedings (Item entry PDF). |
Why this ruling matters
1. Protects candidates with multi-disciplinary degrees: Many universities award degrees with varied nomenclature; candidates who have studied the required core subjects should not be thrown out on technicalities. :contentReference[oaicite:8]{index=8}
2. Promotes purposive interpretation in recruitment: Public employers must examine transcripts, syllabus and expert departmental opinions instead of mechanically rejecting applications on the basis of titles alone. :contentReference[oaicite:9]{index=9}
3. Applies beyond a single contractual post: Although this litigation involved a contractual appointment, the Court emphasized that the State remains bound by fairness and reasonableness even in contractual decisions.
What this does NOT allow
- It does not permit declaring an unrelated degree eligible where the required subject is not studied.
- It is not an academic equivalence order (i.e., it does not change degree nomenclature in universities) — it is an interpretation of recruitment eligibility.
Primary sources & reporting (useful for verification)
- LiveLaw — report on the judgment.
- Full judgment PDF (copy on Verdictum) — 18 pages PDF containing the Court’s reasoning and orders.
- LawCurb — case summary & citation. :contentReference[oaicite:14]{index=14}
- Supreme Court API / Record of Proceedings (Item PDF) — official Court item entry and procedural record.
- LawGico — additional coverage & summary
Notes on the PDF links
The Verdictum PDF (linked above) is a full copy of the judgment as uploaded by that portal (it contains the Court’s reasons and the operative orders). The Supreme Court API / main site hosts the Record of Proceedings and (when uploaded) the final judgment PDF — the API item link included above is the official procedural entry related to this SLP (Special Leave Petition) and provides the docket/ROPs entry. For the authoritative official PDF judgment, you can also search the Supreme Court’s Judgments repository by the party name / date indicated in the Verdictum / LiveLaw reports.
Conclusion
This ruling is a practical reinforcement of the principle that, in recruitment, substance should trump form. When a candidate has demonstrably studied the required core subject, a mechanical fixation on the degree's printed title should not deny access to employment opportunities. Employers and recruitment authorities are urged to adopt a purposive approach and examine curricular evidence when assessing eligibility. :contentReference[oaicite:18]{index=18}
Editorial note: This article links to publicly available documents and reporting found on the web. The full judgment copy used here is the Verdictum-hosted PDF (linked earlier). The Supreme Court's official portal and API contain the record of proceedings for this matter; search by party name or diary number for the official posted PDF when it appears on the SC website. If you want, we can also prepare a downloadable PDF of this article (branded for your site) or a short social media summary for distribution.
