Punjab & Haryana HC: Higher Academic Degree Can’t Replace Mandatory Professional Qualification; Equivalence of Educational Qualifications Must Be Decided by Expert Bodies, Not Courts
Case Name: Sharda Devi v. State of Haryana and Others
Date of Judgment: 15 July 2026
Citation: CWP-21266-2026
Bench: Justice Harpreet Singh Brar
Held: The Punjab and Haryana High Court held that an M.A. (Fine Arts/Painting) is an academic qualification and cannot substitute the mandatory professional qualification of B.Ed. with Art as a teaching subject prescribed under the Haryana School Education (Group-C) State Cadre Service Rules, 2023. The Court ruled that the petitioner did not possess the essential qualification on the prescribed cut-off date and that the doctrine of higher qualification in the same line was inapplicable. It further held that questions relating to equivalence of educational qualifications fall within the domain of expert bodies and not the writ court. Accordingly, the rejection of the petitioner’s candidature for the post of TGT (Arts) was upheld.
Summary: The petitioner challenged the order rejecting her candidature for appointment as a TGT (Arts) pursuant to Advertisement No. 2/2023 issued by the Haryana Staff Selection Commission. Although she had successfully cleared the selection process and her name appeared in the final selection list, her candidature was rejected on the ground that she did not possess B.Ed. with Art as a teaching subject on the cut-off date of 15 March 2023. She argued that her qualifications, including M.A. (Fine Arts/Painting), B.Ed., HTET, and an additional teaching subject in Arts, together with Government Instructions dated 25.03.2016 and the Full Bench decision in Manjit Singh v. State of Punjab, entitled her to be treated as possessing a higher qualification in the same line.
The State contended that the statutory recruitment rules specifically required a professional teaching qualification, namely B.Ed. with Art as a teaching subject, which the petitioner acquired only on 21 December 2023, well after the prescribed cut-off date. It further submitted that an academic postgraduate degree in Fine Arts could not be equated with a professional teacher-training qualification.
The High Court accepted the State’s submissions and held that the ratio in Manjit Singh applies only where the higher qualification is in the same discipline and incorporates the curriculum of the prescribed qualification. The Court observed that an M.A. (Fine Arts/Painting) imparts academic knowledge, whereas B.Ed. with Art as a teaching subject provides professional pedagogical training required under the statutory rules. Since the petitioner failed to establish equivalence between the two qualifications, the Court declined to treat her postgraduate degree as a higher qualification in the same line. It further reiterated that determination of equivalence of educational qualifications is a matter for the employer or expert authorities and not for judicial determination in writ proceedings. As the petitioner lacked the prescribed qualification on the cut-off date, the rejection of her candidature was found to be lawful.
Decision: The writ petition was dismissed. The High Court upheld the rejection of the petitioner’s candidature, holding that she did not possess the mandatory professional qualification of B.Ed. with Art as a teaching subject on the cut-off date and that her M.A. (Fine Arts/Painting) could not substitute or be treated as an equivalent higher qualification under the applicable recruitment rules.