Candidates Must Have Specific Undergraduate Qualifications In The Subject They Intend To Teach, Regardless Of Any Higher Qualifications: MP High Court
The Madhya Pradesh High Court dismissed a writ petition challenging the rejection of an application for a teaching position ruling that possessing a Master's degree in English does not fulfill the mandatory requirement of having a Bachelor's degree in English, as stipulated by the Madhya Pradesh School Education Services (Teaching Cadre) Recruitment Rules, 2018.
The petitioner applied for the position of Madhyamik Shikshak (Class-II Teacher) in English, as advertised by the Madhya Pradesh government. His qualifications included a Bachelor's degree in Political Science, Hindi Literature, and Sanskrit, along with a Master's degree in English. After his application was rejected on the grounds that he did not meet the required educational qualifications, Sharma filed a writ petition.
A Bench of Justice Anil Verma said, “when the post is English Teacher, then it is but natural that the study must be regular basis in graduation of three years in that very subject. The study of that subject through any other mode or an compartmental basis, without regular studies in a bachelors course for Arts, can in no way be treated as equivalent. Therefore, petitioner is not having the minimum qualification for the post of Madhyamik Shikshak ( Subject- English) and he does not deserve any relief.”
Advocate Rakshit Gupta appeared for the petitioner and Government Advocate G.K. Agrawal appeared for the respondents.
The Madhya Pradesh School Education Services (Teaching Cadre) Recruitment Rules, 2018, specify that a Bachelor's degree in the relevant subject (English) is a fundamental requirement for the position of Madhyamik Shikshak, in addition to a B.Ed. degree. The Court underscored that this requirement is unequivocal and must be adhered to by all candidates applying to teach English.
The Court emphasized that educational qualifications for teaching positions must include formal training in the subject at the undergraduate level. A candidate lacking formal undergraduate education in English cannot be expected to possess the same level of competency as someone who has studied the subject extensively for three years during their Bachelor's program.
The Court reasoned that postgraduate qualifications cannot replace the basic educational standards outlined in the recruitment rules. The Court maintained that strict adherence to prescribed qualifications is essential for ensuring fairness and consistency in the selection process, thereby preventing arbitrary exceptions or relaxed standards that could compromise the integrity of recruitment.
Consequently, the Court concluded that deviating from the established criteria of the recruitment rules would undermine the merit-based selection process and set a troubling precedent for future recruitments.
Ultimately, the Court dismissed the petition, affirming that his qualifications were inadequate for eligibility for the post and that no relief could be granted.
Cause Title: Lakshmi Kant Sharma v. The State of Madhya Pradesh & Ors.