Supreme Court Orders Reinstatement of Contractual Consultant; Holds State Acted Arbitrarily by Ignoring Curriculum Showing Required Statistics Qualification

Case Name: Laxmikant Sharma v. State of Madhya Pradesh & Others
Citation: 2025 INSC 1385
Date of Judgment/Order: 04 December 2025
Bench: Sanjay Karol, J.; Vipul M. Pancholi, J.

Held: The Supreme Court held that the State of Madhya Pradesh acted arbitrarily and unreasonably in terminating the appellant’s contractual engagement on the ground that he did not possess a “postgraduate degree in Statistics.” The Court ruled that the appellant’s M.Com. degree, which included Business Statistics and Indian Economic Statistics as principal subjects, substantively satisfied the qualification prescribed in the advertisement when read purposively. The repeated reliance on an inquiry committee report that was factually incorrect and prepared without hearing the appellant violated natural justice. The State also failed to consider the expert opinion of its own Director, who categorically certified the appellant’s eligibility. Singling out the appellant while similarly qualified candidates continued in service amounted to hostile discrimination under Article 14.

Summary: The appellant was appointed in 2013 as Monitoring and Evaluation Consultant under the Water Support Organization of the Public Health & Engineering Department. His services were abruptly terminated following an inquiry report stating he did not possess a postgraduate degree in Statistics. In multiple rounds of litigation, the High Court repeatedly remanded the matter for reconsideration, during which (i) the University certified in 2019 that the appellant’s M.Com. curriculum included core Statistics subjects, and (ii) the Director of the Department issued a detailed recommendation confirming he met the prescribed qualification and had performed satisfactorily. Nonetheless, the State persisted with termination, mechanically reiterating that only a degree explicitly titled “Statistics” would suffice—even though no such course existed in any government university in Madhya Pradesh. The Supreme Court examined the advertisement, curriculum records, expert recommendations, and the State’s inconsistent approach toward similarly placed candidates. It held that the authorities failed to apply a rational and fair standard, ignored material documents, violated natural justice, and acted in disregard of constitutional obligations even while exercising contractual powers.

Decision: The Supreme Court allowed the appeal, set aside the High Court’s judgment dated 20 September 2024, and ordered that the appellant be reinstated to the post of Monitoring and Evaluation Consultant within four weeks, with all consequential benefits. The Court clarified that the judgment was confined to the peculiar facts of the case and was not to be treated as a precedent. All pending applications were disposed of.